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How the Substantial Increase in False Claims Act Penalties Affects the Litigation Landscape

Client Alert | less than 1 min read | 08.01.16

On June 30, 2016, DOJ, pursuant to Congressional mandate, published an interim final rule nearly doubling the penalty range for violations under the civil False Claims Act. In a "Feature Comment” published in The Government Contractor, C&M attorneys analyze the new rule, the implications of dramatically increased penalty amounts on False Claims Act litigation, and the likely effect on federal government contractors.

Insights

Client Alert | 2 min read | 02.03.26

CMS Doubles Down on RADV Audit Changes

On January 27, 2026, the Centers for Medicare and Medicaid Services (CMS) released a Health Plan Management System (HPMS) memo that provided a long-awaited update on how the agency plans to approach previously announced Risk Adjustment Data Validation (RADV) audits for Payment Years (PY) 2020-2024. The memo is the agency’s most comprehensive statement on the subject since September 25, 2025, when the Northern District of Texas vacated the 2023 RADV Final Rule. The memo makes clear that, while CMS has made certain operational adjustments in response to concerns expressed by Medicare Advantage Organizations (MAOs), the agency is largely pressing forward with the accelerated audit strategy announced in May 2025....