(Recorded Webinar) Implied False Certification: How Non-Compliance with Licensure and Certification Requirements May Constitute a Violation under the False Claims Act (June 2017)

Last year, the U.S. Supreme Court handed down a unanimous decision in the case of Universal Health Services vs. Escobar that upheld the theory of implied false certification under the False Claims Act (FCA).  Under that theory, non-compliance with applicable legal requirements can render claims false because the claims imply certification of compliance with material relevant statutes, regulations or contract requirements.  The decision expands the risk of liability under the FCA because compliance with regulatory requirements become conditions of payment.  Health centers are most at risk when a claim makes specific representations about the goods or services (such as the proper licensure of employees or the health center) because the health center’s failure to disclose noncompliance makes those representations misleading half-truths.  
This webinar will provide an overview of the Supreme Court decision, provide examples of the types of cases in which this theory has been successfully applied, and identify specific licensing and certification requirements applicable to health centers that could form the basis for FCA liability under the theory of implied false certification. 
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Adam Falcone

Adam J. Falcone is a partner in FTLF’s national health law practice group, where he counsels a diverse spectrum of community-based organizations that render primary and behavioral healthcare services. Adam counsels clients on a wide range of health law issues, with a focus on fraud and abuse, reimbursement and payment, and antitrust and competition matters. [Full Bio]

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