On September 1, 2026, the Eleventh Circuit issued its highly anticipated decision in United States ex rel. Zafirov v. Fla. Med. Assocs., LLC, holding that the False Claims Act’s qui tam provision does not violate the Appointments Clause of the
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First Healthcare Company Avoids Criminal Charges Under DOJ’s New Self-Disclosure Policy
On July 29, 2026, the Department of Justice (“DOJ”) announced that it declined to bring criminal charges against Campus Eye Management Holdings LLC and its subsidiary, Campus Eye Management LLC (collectively “Campus Eye”), a New Jersey-based management services organization. Campus
CMS Proposes Provider Enrollment Changes to Strengthen Program Integrity
On July 6, 2026, the Centers for Medicare & Medicaid Services (CMS) published its Calendar Year 2027 Home Health Prospective Payment System Proposed Rule (the “Proposed Rule”) in the Federal Register, which includes several provider enrollment changes that would be
DoW Suspends CMMC Phase II Requirements – Launches 60-Day Review
On July 13, 2026, the Department of War (DoW) announced the immediate suspension of all Cybersecurity Maturity Model Certification (CMMC) Phase II requirements, which had originally been scheduled to take effect Nov. 10, 2026, including the transition to mandatory third-party
OIG Clears Pathway for Free Supplemental Cancer Screening Report
AI-Assisted Billing Could Create FCA Pitfalls: How Healthcare Companies Can Get Ahead of Risk
Across the healthcare industry, providers are increasingly relying on AI-assisted billing tools to automate medical coding, prior authorization workflows, and the submission of claims to Medicare, Medicaid and other federal payors. The efficiency gains can be substantial, as can the
How Federally Funded Organizations Should Prepare for OMB Proposed Overhaul of Grants Oversight, DEI Bans, Easier Terminations
As part of the Trump administration’s efforts to implement a broad range of executive orders targeting diversity programs and other policy priorities in federal grantmaking, OMB published a proposed rule on May 29, 2026, that would substantially revise the Uniform
Canadian Steel Companies and Owner to Pay $19M to Settle False Claims Act Allegations Relating to Evaded Customs Duties
On May 20, 2026, the DOJ announced a settlement under the False Claims Act (FCA) with two Canada-based steel companies, Farjess Inc. and Royal Canadian Steel Inc., and their part-owner and president, Feroz Jessani. They agreed to pay $19 million
DOJ’s New West Coast Strike Force Puts Health Care Providers on Notice
The DOJ’s National Fraud Enforcement Division announced on April 30, 2026, the formation of the West Coast Health Care Fraud Strike Force, a multi-district enforcement initiative spanning Arizona, Nevada and the Northern District of California. Announced by Assistant Attorney General
HHS Inspector General Reminder: Kickback Liability Turns on Intent, Not Market Value or Stark Law Compliance
The U.S. Department of Health and Human Services Office of Inspector General (OIG) updated its FAQs on Fraud and Abuse Authorities to add a new answer on fair market value (FMV) in FAQ 17 and revise the answer on how