|

FDA approvedThe United States Department of Justice (“DOJ”) has intervened in two False Claims Act suits filed against the pharmaceutical giant Novartis, alleging the company paid unlawful kickbacks to physicians and pharmacies in violation of federal law. Novartis is the second-largest pharmaceutical company in the world by sales, the global headquarters of which are located in Basel, Switzerland, and American operations based in New Jersey. Both suits were filed in the U.S. Attorney’s Office for the Southern District of New York, located in Manhattan. The suits allege violations of a federal law known as the Anti-Kickback Statute.

In the first suit filed by federal prosecutors,  the United States alleges that Novartis paid kickbacks to pharmacies in exchange for switching patients from CellCept, a brand name immunosuppressant manufactured by Hoffmann-La Roche (a competing Swiss pharmaceutical company), or a generic version, to Myfortic, Novartis’s immunosuppressant drug. The payments to pharmacies were characterized as “rebates” and “discounts,” a common practice by which drug companies seek to disguise unlawful attempts to induce pharmacy referrals of drugs to be reimbursed by federal health insurance programs.

Only days later, a second suit was filed in connection with Novartis’s allegedly pervasive use of kickbacks to physicians in exchange for prescriptions of Novartis products. According to the complaint, Novartis paid doctors “honoraria” fees for endorsing and speaking about certain drugs, including hypertension drugs Lotrel and Valturna as well as its diabetes medication, Starlix. While it is not per se unlawful for physicians to accept compensation for appearing at events sponsored by pharmaceutical companies or speaking favorably about a company’s drug, such fees are often nothing more than unlawful kickbacks in disguise. In this case, the government claims that Novartis sponsored events and paid doctors to attend events which were essentially social gatherings for doctors with only de minimis educational value. In many instances, doctors spent little or no time discussing the drugs at issue, and some of the purported speaker events either did not occur at all or had very few attendees. The kickback scheme is also alleged to have included elaborate dinners; one such meal at a restaurant in Washington, D.C. cost $672 dollars per person.

Continue reading ›

|

PageLines- itsyourdecision.jpgThe United States Department of Justice (“DOJ”) has filed a complaint in D.C. federal court against the former seven-time Tour de France champion cyclist Lance Armstrong, alleging that Mr. Armstrong defrauded the United States through use of performance-enhancing drugs. The complaint in the case, U.S. ex rel. Floyd Landis v. Tailwind Sports Corp., contains six counts, including violations of the False Claims Act, as well as common law claims of fraud and unjust enrichment. DOJ has intervened in a complaint filed under the qui tam (whistleblower) provisions of the False Claims Act by Armstrong’s former teammate, Floyd Landis. In addition to Armstrong, the named defendants in the case include Armstrong’s former team manager Johan Bruyneel, Tailwind Sports Corp. (owner of Armstrong’s cycling team), and Thomas Weisel, who was the founder and principal investor in Tailwind. A claim for breach of contract was brought against Tailwind. 

Under the False Claims Act, entities which submit (or cause to be submitted) false claims for payment to the government are liable for treble damages and civil penalties of between $5,500 and $11,000 per violation. The application of the Act continues to broaden, particularly in the wake of Congress’s passage of the Fraud Enforcement and Recovery Act (“FERA”) (2009), the Dodd-Frank Wall Street Reform and Consumer Protection Act (2010) and the Patient Protection and Affordable Care Act (2010). The recent congressional enactments have given impetus to the government’s effort to hold violators liable in the realms of mortgage and lending fraud as well as fraud and abuse in the health care sector. FERA, in particular, heightened the protections against employer retaliation contained in the False Claims Act as the United States encourages private individuals with knowledge of fraud to sue under the Act’s qui tam provisions. Whistleblowers (known as “relators”) sue on behalf of the government, and must disclose the allegations in the qui tam complaint to the DOJ. After an initial investigatory period, the United States may either elect to intervene in a relator’s complaint or decline to do so, but in either case the private suit may go forward. Qui tam complaints are a crucial vehicle by which private citizens may supplement the necessarily limited enforcement capacity of the federal government; employees and other individuals with knowledge on the ground are often better-situated than the government to police violations of the False Claims Act.

In Landis’s original complaint, he alleged that Armstrong knowingly contravened his agreement with the U.S. Postal Service, from which Armstrong’s team accepted money. As part of the agreement, Armstrong promised not to engage in the use of any illicit performance-enhancing drugs; it is this sponsorship agreement which gives rise to potential False Claims Act liability. Under the contract with the U.S. Postal Service, the government paid a total of $30.6 million; the government’s total recovery in a lawsuit against Armstrong could thus approach $100 million. Other named defendants in the suit are reported to be Thom Weisel, erstwhile head of the management company that owned Armstrong’s cycling team, and Johan Bruyneel, the former team director.

Continue reading ›

|

Doctor with PillsAmgen, a California-based biotechnology company, has reached a settlement with the United States Department of Justice (DOJ), as a result of which the company will pay $24.9 million to resolve claims of Medicare and Medicaid fraud brought under the False Claims Act. The United States alleges that Amgen paid unlawful kickbacks to long-term care facility pharmacy providers in exchange for steering Medicare and Medicaid patients to use of the drug Aranesp, Amgen’s anti-anemia drug. The pharmacy providers are alleged to be Omnicare Inc., PharMerica Corp., and Kindred Healthcare Inc. Kickbacks were paid in proportion to the volume of the drug purchased by each pharmacy, according to the government’s complaint. Providers that participate in federal health insurance programs are prohibited under the federal Anti-Kickback Statute (“AKS”) from offering or soliciting remuneration in exchange for referrals resulting in the purchase of a product or service eligible for reimbursement by the federal program. While not all such payments are illegal, payments which vary depending upon the volume of referrals are usually condemned by the statute. Providers that seek reimbursement under Medicare or Medicaid despite non-compliance with federal statutes such as the AKS may be liable for submitting, or causing to be submitted, false claims for payment in violation of the False Claims Act.

The Amgen kickbacks were allegedly paid in the form of grants, honoraria, speakers’ fees, and travel expenses to employees at the pharmacy providers. In return, according to the government, the pharmacies implemented a “therapeutic interchange” program whereby nursing home patients were taken off of a competing firm’s anti-anemia medication and switched to Aranesp. Consequently, the Medicare and Medicaid programs paid for countless Aranesp prescriptions for which reimbursement was not permitted because the referrals resulted from unlawful kickbacks. Additionally, the United States claimed that Amgen pressured some pharmacists to recommend use of Aranesp for patients for whom the drug was not medically necessary. Under the terms and conditions of participation, Medicare and Medicaid do not reimburse for medically unnecessary medical care, and such promotion by the drug’s manufacturer may also have violated the Federal Food, Drug, and Cosmetic Act (“FDCA”), which prohibits pharmaceutical manufacturers from promoting drugs for uses unapproved by the FDA or for medically unnecessary uses.

Initially, the allegations against Amgen were made in a private whistleblower suit filed under the qui tam provisions of the False Claims Act. Under the qui tam provisions, individuals with knowledge of fraud against the government may sue on behalf of the United States. Qui tam suits are filed under seal, and subsequently the whistleblowers (referred to as “relators”) disclose the allegations in the complaint to the DOJ. After an initial period of investigation, the DOJ determines whether or not the United States will exercise its right to intervene in the litigation. Regardless of whether the government intervenes, relators may proceed privately with their claims and receive an award equal to a percentage of the government’s total recovery. A relator who prevails without government intervention stands to recover between 25-30% of any final judgment or settlement in favor of the United States. In the Amgen case, the DOJ elected to intervene in a qui tam suit filed in 2011 by a former Amgen employee.

Continue reading ›

|

ElectricityFluor Hanford (“Fluor”), a company contracted by the U.S. Department of Energy to train federal emergency management personnel, will pay $1.1 million to resolve claims that it defrauded the government by using appropriated money to lobby the federal government for yet more funding in violation of the False Claims Act. Fluor operated the Hanford Training Center (the “HAMMER” center) under contract with the Department of Energy from 1996 to 2009, and the alleged fraudulent lobbying occurred from 2005 to 2008. Fluor has denied violating any representations made to the government in order to secure the contract and further denies violating federal ethics laws. Initially, according to the government’s False Claims Act complaint, Fluor focused on expanding the scope of its operation by marketing the training center to regional first responders such as the Seattle Fire Department. When these efforts proved inadequate to increase the profitability of the training facility, Fluor hired two lobbying firms, Congressional Strategies and Secure Horizons Consulting, to promote the HAMMER center. The government alleged that these consulting firms lobbied members of Congress and federal agencies to increase appropriations in agencies’ budgets for HAMMER. The consulting firms were paid substantial sums for their services; documents filed in the case show that Congressional Strategies was paid $398, 164, while Secure Horizons was paid $278,148.

The government claimed that Fluor certified it would not use any taxpayer funds for lobbying purposes, and thus claims for payment pursuant to its contract with the Department of Energy violated the False Claims Act. Companies seeking to secure government contracts must agree to abide by a whole host of conditions and certify compliance with a constellation of federal laws in order to be awarded any contract. Under the False Claims Act, a government contractor may be liable when seeking reimbursement in a number of contexts: defective performance, failure to perform according to specifications set out in the contract or otherwise provided for by law, or non-compliance with other federal statutes and regulations (such as federal ethics laws). In this case, the government alleges that Fluor Hanford expressly certified as a condition of the contract that it would not use appropriated funding to lobby for additional congressional appropriations, and thus claims for payment pursuant to the Department of Energy contract constitute false claims under the False Claims Act.

The False Claims Act imposes liability when a person submits a false claim for payment to the government or when a false claim is submitted to reduce or eliminate a liability owed to the government. Moreover, the knowing retention of overpayments can also trigger False Claims Act liability. When a relator files a complaint, the government may review the allegations and elect to intervene in the litigation; however, the government does not always do so. Even if the government does not intervene, a relator may proceed privately. If successful, relators stand to recover between 15% and 30% of any final judgment or settlement. In the year 2012 alone, the United States saw a record $5 billion in False Claims Act recoveries. The Act allows for civil penalties of as much as $11,000 per violation in addition to trebling of damages.

Continue reading ›

|

Talking to PatientTechota LLC, a home health care company, has agreed to a $150,000 settlement agreement with the United States to resolve all claims of liability under the federal False Claims Act. According to a complaint filed under the qui tam (whistleblower) provisions of the Act, Techota provides home health care services in Alabama, operating under the names CV Home Health of Bibb County and CV Home Health Services. The False Claims Act is an anti-fraud statute which imposes liability on individuals and companies that submit or cause to be submitted false claims for payment to the government. The complaint alleged that Techota submitted false claims for payment to Medicare, seeking reimbursement for home health care services that were either not medically necessary or not provided pursuant to an appropriate care plan as required by law. Providers must agree to the terms and conditions of the program in order to participate in Medicare, and participating providers must certify that all services for which reimbursement is sought are medically necessary. Federal regulations also require home health care providers to develop care plans and administer medical services pursuant to those plans. Billing for medically unnecessary products and services gives rise to liability under the False Claims Act. In addition to the $150,000 payment, Techota has also entered into a corporate integrity agreement with the Office of the Inspector General of Health and Human Services, a remedy often employed by the Justice Department in health care fraud cases to ensure continued oversight and monitoring of compliance with federal laws governing health care.

The qui tam suit was initially filed in Alabama federal court by whistleblower Veronica McDonald, a former employee of Techota. Under the qui tam provisions of the False Claims Act, private individuals with knowledge of fraud perpetrated against the United States have standing to file complaints on behalf of the government. After an initial statutory investigation period, the government decides whether or not to intervene in a particular case, but relators may proceed with their claims even if the government declines to intervene. Under the statute, violators are subject to treble damages and civil penalties of as much as $11,000 per false claim; whistleblowers (known as relators) stand to receive an award ranging between 15% and 30% of the government’s total recovery. For filing her qui tam complaint that ultimately led to the settlement with Techota, McDonald will receive an award of $22,500.

In recent years, amendments to the False Claims Act have aimed to expand the ambit of the statute’s anti-fraud provisions and increase the anti-retaliation protections available to whistleblowers. In the wake of passage of the Fraud Enforcement and Recovery Act of 2009, the Dodd-Frank Financial Reform law in 2010, and the Patient Protection and Affordable Care Act (“PPACA”) in 2010, the government has begun to vigorously pursue cases of financial fraud and mortgage and lending fraud. PPACA also included provisions amending the False Claims Act designed to increase the tools available to prosecute claims of health care fraud and abuse.

|

Court ReportersIn United States ex rel. Nathan v. Takeda Pharmaceuticals, an opinion handed down by the United States Court of Appeals for the  Fourth Circuit on January 11th, 2013, the Court upheld a restrictive view of the Rule 9(b) pleading standard as applied to claims brought under the False Claims Act. The Court held that a qui tam relator must allege details pertaining to specific false claims submitted to the government in order to survive a motion to dismiss. In so doing, the Court rejected the more flexible approach to application of the 9(b) pleading standard adopted by the Fifth Circuit in United States ex rel. Grubbs v. Kanneganti (2009) and (implicitly) by the Eleventh Circuit in U.S. ex rel. Walker v. R&F Properties of Lake County, Inc., furthering a circuit split that will not be resolved unless and until the Supreme Court has occasion to decide the question in future litigation.

The False Claims Act, 31 U.S.C. § 3729 et seq., is a federal statute that prohibits individuals and companies from presenting (or causing to be presented) false claims for payment to the United States government. Enacted in 1863 to deter fraud by private contractors against the Union Army, the law has evolved into a capacious vehicle through which the government protects the Treasury and combats fraud. Successive amendments to the statute, including passage of the Fraud Enforcement and Recovery Act in 2009, the Dodd-Frank Wall Street Reform  Act in 2010, and the Patient Protection and Affordable Care Act (“PPACA”) in 2010, have enhanced the tools at the government’s disposal and expanded the ambit of conduct actionable under the Act. In furtherance of the statute’s remedial purpose, the law contains qui tam provisions which allow private whistleblowers, referred to as relators, to file complaints under seal. While a qui tam complaint is under seal, the allegations are disclosed to the government, which then investigates the claim and makes a determination as to whether or not the United States will exercise its right to intervene in the litigation.

As is the case with all federal statutes (especially those involving suits between private parties), the task of interpreting its provisions and fashioning procedural rules governing litigation under the False Claims Act is incumbent upon the federal courts. Of particular interest to relators filing claims under the False Claims Act is the pleading standard governing the sufficiency of a qui tam complaint. Although most types of legal claims in federal court are subject to the relatively liberal pleading standard set forth in Rule 8(a) of the Federal Rules of Civil Procedure, requiring a “short plain statement” describing the claim for which relief is sought, Rule 9(b) requires that claims of fraud be pleaded with “particularity.” Specifically, Rule 9(b) says that a party alleging “fraud or mistake must state with particularity the circumstances constituting fraud or mistake.” Consequently, the federal appeals courts have had little difficulty holding that the heightened pleading requirement of Rule 9(b) applies to qui tam complaints and government prosecutions under 31 U.S.C. § 3729 (a) (1-3). Because the Supreme Court has limited the application of Rule 9(b) to those causes of action enumerated in the rule itself, the heightened pleading standard does not apply to other claims under the False Claims Act (as the Ninth Circuit held, for example, in Mendiondo v. Centinela Hospital Medical Center, 521 F.3d 1097 (2008)).

Continue reading ›

|

Talking to PatientNew Jersey-based Cooper Health System and Cooper University Hospital have agreed to a $12.6 million settlement to resolve claims of Medicare and Medicaid fraud in violation of the False Claims Act. The agreement was the result of a multi-year investigation by the United States Department of Justice (“DOJ”) and the New Jersey Attorney General’s Office; the government learned of the alleged conduct through disclosures  by Dr. Nicholas DePace in a qui tam suit filed in 2008.

Dr. DePace filed suit under the qui tam provisions of the False Claims Act, which allow private whistleblowers (referred to as “relators”) with knowledge of fraud to file suit on behalf of the government. The federal False Claims Act dates back to 1863, enacted to combat war profiteering during the Civil War. Thirty states and three municipalities have enacted statutes modeled on the federal law, including qui tam provisions providing for private rights of action for qui tam relators. Dr. DePace is a prominent Philadelphia-area cardiologist.

The government alleged that the Cooper Health System and hospital (“Cooper”) paid millions of dollars in remuneration to physicians in order to induce referrals in violation of the Anti-Kickback Statute (“AKS”). The AKS makes it a felony for any person to offer, solicit, receive, or pay remuneration in connection with a referral for services that are eligible for reimbursement under a federal health care program such as Medicare or Medicaid. Medicaid is a program that is administered by both the federal government and the states, and consequently state attorneys general frequently investigate and assist in prosecuting Medicaid fraud under state false claims acts. Both the United States and the State of New Jersey intervened in Dr. DePace’s qui tam complaint. Under the False Claims Act, the government has an initial 60-day period in which to determine whether or not to intervene in a qui tam suit, but relators may continue to pursue their claims privately even if the government declines to intervene.

Continue reading ›

|

FDA approvedA recent opinion handed down by a panel of the United States Court of Appeals for the Second Circuit in U.S. v. Caronia has raised serious questions about the constitutionality of criminal prosecutions for illegal promotion of drugs under the Federal Food, Drug, and Cosmetic Act (“FDCA”), a statute which many proponents of consumer protection regard as indispensable for the effective regulation of drug safety in the United States. Alfred Caronia, a Specialty Sales Consultant hired by Orphan Medical, Inc. (a drug manufacturer since acquired by Jazz Pharmaceutical) in March of 2005 to promote the drug Xyrem, was convicted on two counts of misbranding and conspiracy to misbrand under the FDCA in 2009 after a jury trial in federal district court in Long Island, NY. Caronia appealed his conviction to the Second Circuit, which has jurisdiction over the federal district courts in New York State, Connecticut, and Vermont, and the panel vacated his conviction on the grounds that criminal convictions predicated upon the “off-label” promotion of drugs (that is, promotion of drugs for indications not approved by the FDA) constitute speaker- and content-based restrictions of speech in violation of the First Amendment. The panel’s decision was 2-1, with a vigorous dissent from Circuit Judge Debra Livingston.

The text of FDCA §331(a) prohibits the “misbranding” of drugs; a drug is defined as “misbranded” if, among others, the manufacturer fails to provide adequate instructions for the intended use of the drug under §352(f). Furthermore, regulations promulgated by the FDA make clear that the government may demonstrate a drug’s intended use through evidence of statements in promotion of the drug for uses for which it is neither labeled nor advertised. Thus, when pharmaceutical representatives promote the use of a drug for indications unapproved by the FDA, the conduct is probative of misbranding in violation of the FDCA. While the federal government investigates misbranding offenses for the purposes of criminal prosecution, the practice of off-label promotion also gives rise to false claims under the federal False Claims Act. Off-label promotion was first recognized by a court as actionable fraud under the False Claims Act in 2003, when U.S. District Judge Patti Saris denied summary judgment in a False Claims Act suit alleging off-label promotion by Warner-Lambert and Pfizer. Since the novel theory was validated in 2003 (culminating in a historic $430 million settlement in 2004), off-label promotion has led to billions of dollars in recoveries for both the government and private whistleblowers filing suit under the qui tam (whistleblower) provisions of the False Claims Act. Whistleblowers (known as “relators”) who file suit under the False Claims Act may recover between 15% and 30% of any final judgment or settlement as a reward for coming forward.

Xyrem was approved by the FDA in 2002  for narcolepsy patients who experience cataplexy, a condition associated with weak or paralyzed muscles. In 2005, the FDA approved Xyrem to treat narcolepsy patients with excessive daytime sleepiness (“EDS”), a neurological disorder caused by the brain’s inability to regulate sleep-wake cycles. Xyrem’s active ingredient is gamma-hydroxybutryate (“GHB”), commonly referred to as the “date rape drug” due to its prevalence in the commission of sexual assaults, and consequently the FDA limited the drug’s approval to the two indications and required the manufacturer to place a “black box” warning on the label. A black box warning is the most serious type of warning that the FDA can mandate; among others, Xyrem’s black box warning disclaimed the drug’s efficacy in patients under 16 years of age as well as the elderly. Careful FDA regulation of potentially harmful drugs such as Xyrem is intended to ensure that consumers are not exposed to unreasonable danger from use.

Continue reading ›

|

Doctor with ChecklistAmerican Sleep Medicine LLC, a Florida-based company that owns 19 diagnostic sleep testing centers throughout the United States, has agreed to pay over $15.3 million to resolve claims that it submitted false claims for payment to Medicare and two other federal health insurance programs in violation of the False Claims Act. The government alleged that the company billed Medicare, the Railroad Retirement Medicare Program, and TRICARE (a military health care program) for sleep diagnostic services performed by technicians who lacked the requisite certifications under the federal programs. Under the health programs, sleep technicians must be credentialed by a state or federal licensing body, and the government alleged that American Sleep Medicine knew that technicians who lacked such credentials were performing tests for which reimbursement was sought. Consequently, several federal programs and departments, including the Department of Defense (which administers TRICARE) as well as the federal Medicare program, paid for sleep testing services that were ineligible for reimbursement.

The United States Department of Justice (“DOJ”) was apprised of the allegations through the disclosure filed in a private whistleblower suit by relator (whistleblower) Daniel Purnell. The suit was filed under the qui tam provisions of the False Claims Act, which allow private individuals (known as relators) to sue on behalf of the government for fraud perpetrated against the government. Under the statute, qui tam relators must disclose the allegations to the government, and subsequently federal investigators have an initial 60-day period in which to review the claims and determine whether or not the federal government will intervene in the litigation. If the government declines to intervene, relators may elect to continue prosecuting their claims; if they prevail, relators stand to recover between 15% and 30% of any final judgment or settlement. Increasingly, government recoveries under the False Claims Act, which soared to a record $5 billion for the year 2012 alone, have come to depend upon information arising out of qui tam complaints. Qui tam recoveries are particularly significant in cases of fraud and abuse in federal health programs, which intake billions of dollars in claims on an annual basis and operate by complicated billing codes. In addition to fraudulent billing, False Claims Act liability exists in cases where individuals or providers knowingly retain overpayments from the government (referred to as “reverse false claims”). Courts continue to recognize a growing number of types of fraud under the False Claims Act, including mortgage and financial fraud, health care fraud and abuse, federal contracting fraud, and off-label promotion of drugs by pharmaceutical manufacturers. For his participation in the American Sleep Medicine case, Mr. Purnell will receive an award of over $2.6 million.

Thirty states have enacted their own versions of the federal False Claims Act, and state treasuries, too, have seen the recovery of billions of dollars to state Medicaid funds, state health insurance programs (e.g., Medi-Cal, a state health program for beneficiaries in the State of California), and state contracts and programs. Since 2009, the federal law also contains strong protections for contractors, agents, and employees against retaliation for conduct protected under the Act. Any employee, contractor, or agent who takes lawful efforts to stop a violation of the False Claims Act may seek the law’s anti-retaliation protections.

|

Medicine Test TubeA subsidiary of Orthofix International SV, Blackstone Medical Inc., has agreed to pay the federal government $30 million to resolve allegations that Blackstone remunerated doctors with illegal kickbacks in order to induce the use of its products. Orthofix is a manufacturer of spinal implants and other products used in spinal surgeries. The government’s complaint, filed under the federal False Claims Act, alleges that Blackstone offered kickbacks to spinal surgeons in order to incentivize orders of its products; the payments are alleged to have been made in numerous guises, including so-called “consulting agreements,” payment of royalties, research grants, travel, and even entertainment. These sorts of payments to doctors may constitute violations of the Anti-Kickback Statute, a federal law that makes it a criminal offense to offer or receive payments in order to induce the utilization of health care products and services. In addition to being prosecuted criminally, violators of the Anti-Kickback Statute often face civil liability under the False Claims Act, the vehicle through which such claims are frequently resolved by the federal government. As part of its settlement with the federal government, Blackstone has agreed to a corporate integrity agreement with the Office of Inspector General of the Department of Health and Human Services, one of the regulatory agencies charged with enforcing anti-fraud laws in the health care sector. Corporate integrity agreements ensure that companies put into place more rigorous oversight and compliance procedures.

The government became apprised of the kickback allegations as a result of a complaint filed under the qui tam (whistleblower) provisions of the False Claims Act. The whistleblower, Susan Hutcheson, is expected to receive $8 million as an award for her participation in the litigation. When a whistleblower (known as a qui tam relator) files a complaint under the False Claims Act, the complaint is sealed and the government has 60 days to review the allegations. Although the government may choose to intervene in the relator’s qui tam complaint, it often does not do so, and relators may proceed with their claims even if there is no government intervention. As was the case in the Blackstone Medical case, the federal government often intervenes for settlement purposes.

Fraud and abuse in federal health insurance programs are pervasive, and the government has increasingly turned to the False Claims Act (particularly qui tam suits) to combat myriad types of fraud, including illegal promotion of drugs by pharmaceutical companies, overbilling of Medicare by providers, and violations of federal laws such as the Anti-Kickback Statute.  The government has recovered $9.5 billion since January 2009 in cases involving fraud against federal health care programs, and total recoveries in False Claims Act cases since January 2009 exceed $13.2 billion.

Continue reading ›
Contact Information
75 Park Plaza 2nd Floor
Boston, MA 02116
Phone: 617.261.0040

This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.

Please do not include any confidential or sensitive information in a contact form, text message, or voicemail. The contact form sends information by non-encrypted email, which is not secure. Submitting a contact form, sending a text message, making a phone call, or leaving a voicemail does not create an attorney-client relationship.

Copyright © 2024, Greene LLP
JUSTIA Law Firm Blog Design