1. Home
  2. |Insights
  3. |DOJ Puts Academic Medical Centers in Spotlight

DOJ Puts Academic Medical Centers in Spotlight

Client Alert | 1 min read | 11.29.12

On November 27, DOJ announced that Baylor University Medical Center has agreed to pay nearly $1 million to settle whistleblower claims brought under the False Claims Act, alleging that Baylor double-billed Medicare for certain procedures and billed for more expensive services when different, less expensive services should have been billed. The settlement, which DOJ hailed as an example of increased cooperation between DOJ and HHS under the Health Care Fraud Prevention and Enforcement Action Team (HEAT) initiative, follows a string of recent cases in which DOJ has targeted higher ed institutions under the FCA.


Insights

Client Alert | 1 min read | 04.18.24

GSA Clarifies Permissibility of Upfront Payments for Software-as-a-Service Offerings

On March 15, 2024, the General Services Administration (GSA) issued Acquisition Letter MV-2024-01 providing guidance to GSA contracting officers on the use of upfront payments for acquisitions of cloud-based Software-as-a-Service (SaaS).  Specifically, this acquisition letter clarifies that despite statutory prohibitions against the use of “advance” payments outside of narrowly-prescribed circumstances, upfront payments for SaaS licenses do not constitute an “advance” payment subject to these restrictions when made under the following conditions:...