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Contractor's Report to OIG Insufficient to Trigger Public Disclosure Bar

Client Alert | less than 1 min read | 03.27.14

In U.S. ex rel Saunders v. Unisys Corp. (E.D. Va.), the court found that the relator's FCA claim was not precluded by the public disclosure bar despite the defendant providing its internal investigation report to OIG because (1) the report failed to reveal allegations or transactions creating an inference of fraud (its conclusion that the alleged fraudulent billing practices were "unacceptable" was not enough) and (2) it was made available only to the DOD IG and the government agency overseeing the contract and not the general public.


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Client Alert | 4 min read | 09.16.26

CMS Offers Guidance as Scrutiny Rises Over ABA Therapy in Medicaid

Between 2021 and 2025, Medicaid spending on ABA therapy grew six times faster than the number of children who received services, making it one of the fastest-growing areas of Medicaid expenditure, according to CMS. On August 4, 2026, CMS released a toolkit to help state Medicaid and CHIP agencies strengthen their programs and limit fraud, waste, and abuse tied to increased demand for ABA therapy. In 2025, Medicaid spent about $10 billion on ABA and related therapy services for children with ASD — a dramatic increase from the $2 billion spent in 2021. ...