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DoD Seeks Changes to the Program Fraud Civil Remedies Act

Client Alert | 1 min read | 04.26.16

On April 12, 2016, DoD sent its legislative proposal package to Congress and requested (in section 805) changes to the Program Fraud Civil Remedies Act to create, in DoD’s view, a more viable administrative remedy for fraud and false claims totaling less than $500,000. In addition to increasing the ceiling on false claims allegations that can be brought under the PFCRA, DoD seeks to place the decision of whether adequate evidence of liability exists in the hands of suspending and debarring officials, raising for contractors serious concerns, some of which are summarized in the associated blog post.

Insights

Client Alert | 6 min read | 03.26.24

California Office of Health Care Affordability Notice Requirement for Material Change Transactions Closing on or After April 1, 2024

Starting next week, on April 1st, health care entities in California closing “material change transactions” will be required to notify California’s new Office of Health Care Affordability (“OHCA”) and potentially undergo an extensive review process prior to closing. The new review process will impact a broad range of providers, payers, delivery systems, and pharmacy benefit managers with either a current California footprint or a plan to expand into the California market. While health care service plans in California are already subject to an extensive transaction approval process by the Department of Managed Health Care, other health care entities in California have not been required to file notices of transactions historically, and so the notice requirement will have a significant impact on how health care entities need to structure and close deals in California, and the timing on which closing is permitted to occur....