Healthcare Fraud Defense
Federal and state investigations, False Claims Act defense, and criminal healthcare fraud cases.

Risk Adjustment Fraud and the FCA
DOJ's 2026 Medicare Advantage settlements show how unsupported HCC codes and one-sided chart reviews become False Claims Act liabi…

Medical Directorship Agreements Under Kickback Scrutiny
A medical directorship survives Anti-Kickback Statute scrutiny only when compensation reflects fair market value for services actu…

Living Under a Corporate Integrity Agreement
A Corporate Integrity Agreement's real work starts at settlement: IRO reviews, a 30-day Reportable Event clock, and stipulated pen…

Reverse False Claims Liability for Retaining an Overpayment
Retaining a known Medicare or Medicaid overpayment past the 60-day deadline can itself be a False Claims Act violation under the r…

Medically Unnecessary Services as an FCA Theory
Medical necessity splits the federal circuits on what counts as false under the FCA, turning a documented clinical judgment into t…

Materiality as a Defense: Government Knowledge
Escobar made FCA materiality a demanding standard. Continued government payment despite knowledge of a violation is very strong ev…

Laboratory Kickback Enforcement: Process and Handling Fees
Specimen processing fees look like overhead reimbursement, but the OIG's 2014 alert and $48.5M in DOJ settlements show how they be…

Individual Accountability in Corporate Healthcare Cases
DOJ's March 2026 Department-wide Corporate Enforcement Policy keeps individual prosecution the priority in corporate healthcare fr…

Insurance Coverage for FCA Defense Costs
A civil investigative demand can trigger D&O coverage before a lawsuit is filed. What a policy actually pays for, and what it excl…
