D.C. Circuit Loosens Public Disclosure Bar While Tightening the Reins on Damages
Client Alert | 1 min read | 05.16.12
In United States ex rel. Davis v. District of Columbia (May 15, 2011), the D.C. Circuit held that recent Supreme Court precedent had abrogated the Circuit's long-standing rule that a relator must provide the government with the information upon which his allegations are based not only before filing an action, but also prior to any public disclosure. The Circuit Court also applied its recent holding in U.S. v. Science Applications Corp., 626 F.3d 1257, that proof of damages requires a showing that, as the result of the alleged fraud, the value of what the government received was less than what it believed it had purchased, finding that, in the matter before it, because there was no allegation that claimed reimbursements were for services not actually received or of inflated value -- only that they lacked documentary support -- "the government got what it paid for and there are no damages."
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Client Alert | 8 min read | 04.17.26
CMS Finalizes CY 2027 Medicare Advantage and Part D Rule: Key Implications for Plan Sponsors
On April 6, 2026, the Centers for Medicare & Medicaid Services (CMS) published its final rule governing the Medicare Advantage (Part C) and Prescription Drug Benefit (Part D) programs for Contract Year (CY) 2027. The final rule is effective June 1, 2026, with most provisions applicable to coverage beginning January 1, 2027, and marketing and communications changes taking effect October 1, 2026. Beyond payment, the rule pursues a broad deregulatory agenda aligned with Executive Order 14192, reversing marketing and enrollment safeguards introduced in 2023 and easing documentation and reporting obligations, while introducing new program integrity requirements.
Client Alert | 1 min read | 04.17.26
Client Alert | 3 min read | 04.17.26
Client Alert | 2 min read | 04.16.26
