False Claims Act Penalties Double with DOJ New Interim Rule

Amanda Bogle Executive Editor Loyola University Chicago School of Law, JD 2017   On June 30, 2016, the Department of Justice joined other agencies in passing a new interim final rule, significantly increasing the penalties for the False Claims Act (FCA). Before, FCA penalties ranged from $5,500 up to $11,000 per false claim. The new …
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New Overtime Rules Have Employers Working Overtime

Ryan Whitney Managing Editor Loyola University Chicago School of Law, JD 2017   Beginning in December of this year, the Department of Labor will implement their final update to the rules governing overtime pay. The new income threshold will nearly double, thus encompassing 4 million workers nationwide. This update will have a large impact on …
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Implied Certification: What does it mean for your small business?

Brittany Tomkies Executive Editor Loyola University Chicago School of Law,  JD 2017   In a monumental decision for false claims cases, the Supreme Court of the United States (SCOTUS) unanimously affirmed the viability of the implied certification theory. The ramifications of this ruling may create additional stressors on small businesses and will likely create additional …
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An Active Summer of Healthcare Fraud Enforcement Actions

Alanna J. Kroeker Executive Editor Loyola University Chicago School of Law,  JD 2017   Unprecedented DOJ Healthcare Fraud Takedown: On Wednesday June 22, Attorney General Loretta Lynch and Department of Health and Human Services (HHS) Secretary Sylvia Burwell announced the largest healthcare fraud takedown in history.  This action was led by the Medicare Fraud Strike …
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Brexit & Privacy Compliance

Ryan Meade Editor-in-Chief Director of Regulatory Compliance Studies at Loyola University Chicago School of Law   Now that the UK referendum has expressed the voters’ preference to leave the European Union, there are some fascinating questions regarding how compliance programs deal with the unwinding.  There is still considerable time to wrestle with these matters since both major …
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Supreme Court Weighs in on Implied False Certification Theory

Ryan Meade Editor-in-Chief Director of Regulatory Compliance Studies at Loyola University Chicago School of Law   The Supreme Court’s decision yesterday in  Universal Health Services, Inc. v. U.S. ex rel Escobar (“UHS”) has had some strange initial summaries suggesting this is a gloom and doom opinion for actors who submit claims to the United States.  I …
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A New Role for Compliance Programs in HHS-OIG Resolutions of Non-compliant Conduct

Ryan Meade Editor-in-Chief Director of Regulatory Compliance Studies at Loyola University Chicago School of Law   A recent commentary from the U.S. Department of Health & Human Services’ Office of Inspector General (HHS-OIG) indicates it will not consider the existence of an effective compliance program as a positive factor in resolving civil non-compliance but it …
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