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DOJ Makes Significant Inflation Adjustment to Civil Monetary Penalties

Client Alert | less than 1 min read | 07.01.16

DOJ published an interim final rule on June 30, 2016, adjusting civil monetary penalties for inflation, that nearly doubles the prior penalty amounts under the Civil False Claims Act from the existing range of $5,500 - $11,000 to a new range of $10,781 - $21,563. The increased amounts, however, apply only to civil penalties assessed after August 1, 2016, for violations that occurred after November 2, 2015, while the penalty amounts for penalties assessed or for violations that occurred before these respective dates remain unchanged.

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Client Alert | 6 min read | 04.29.26

CMS Seeks to Expand Interoperability Requirements to Drug Pre-Authorization (FAQ)

On April 10, 2026, the Centers for Medicare and Medicaid Services (CMS) issued a proposed rule (2026 CMS Interoperability Standards and Prior Authorization for Drugs, or CMS-0062-P) outlining the agency’s plans to impose new interoperability requirements on payors participating in certain Medicare and Medicaid programs. As described by the agency in a recent press release, the proposed rule “builds on” prior rulemaking by clarifying and enhancing interoperability requirements for payors’ prior authorization processes, specifically those associated with coverage requests for pharmaceutical therapies....