“It’s Alive!” High Court Recognizes “Frankenstein’s Monster” Theory of FCA Liability
Client Alert | 1 min read | 06.24.16
In Universal Health Servs. v. U.S. ex rel. Escobar, the Supreme Court unanimously held that a defendant may be liable under the FCA when, in connection with a claim for payment submitted to the government, the defendant “makes specific representations about the goods or services provided” and fails to disclose noncompliance with material statutory, regulatory, or contractual requirements that makes the representations “misleading half-truths.” In a "Feature Comment" published in The Government Contractor, C&M attorneys analyze the Court’s opinion, the legal and factual context in which it arose, and its likely effect on federal government contractors.
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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.
Client Alert | 8 min read | 04.27.26
Client Alert | 5 min read | 04.27.26
Drift Protocol Exploit: Why “Social Trust” Is the Newest Cybersecurity Gap
Client Alert | 4 min read | 04.27.26
Gaming Addiction Litigation: Turner v. Epic Games & Roblox and What It Means for the Industry
