False Statement Liability Involving Federal Grantees Curtailed Again
Client Alert | 1 min read | 10.01.04
Musing that, if 18 U.S.C. 1001 were interpreted to prohibit any false statements to any private entity whose funds in part originated with the federal government, a person who lied about his address to get a local library card could be a federal felon, a divided 11th Circuit panel in U.S. v. Blankenship (Aug. 26, 2004) overturned the criminal convictions of the principal of a Disadvantaged Business Enterprise (DBE) under 18 U.S.C. 1001 because the sham contracts are false certified payroll records that were used to obtain payment under a federally-funded state highway project were not statements made to federal agencies. The Eleventh Circuit's analysis, together with the D.C. Circuit's civil False Claims Act decision in U.S. ex rel. Totten v. Bombardier Corp. (see C&M Bullet Point, Sept. 16) represents a significant cutback of federal authority to sanction contractors doing business with federal grantees.
Insights
Client Alert | 7 min read | 01.30.26
CMS Proposes CY 2027 Growth Rate and Changes to Risk Adjustment for Medicare Parts C and D
On January 26, 2026, the Centers for Medicare and Medicaid Services (CMS) circulated the Calendar Year (CY) 2027 Advance Notice to communicate proposed changes to Medicare Advantage (MA) capitation rates and Parts C and D payment policies. The changes are expected to be finalized in April 2026 but may be delayed. The following is a summary of the most significant proposals, with further details below:
Client Alert | 4 min read | 01.30.26
Optimum’s Shot Across the Bow: An Antitrust Challenge to Cooperation Agreements
Client Alert | 9 min read | 01.30.26
Client Alert | 7 min read | 01.29.26
ASEAN Digital Ministers' Meeting 2026: Spotlight on AI Cooperation in Asia's Rising Markets
