Sample of What's to Come: Extrapolation in FCA Cases
Client Alert | less than 1 min read | 01.20.16
On September 29, 2015, the Fourth Circuit agreed to hear an interlocutory appeal in U.S. ex rel. Michaels. v. Agape Senior Community, Inc., to address whether the statistical method of extrapolation may be used to prove liability and damages under the FCA. In a "Feature Comment" published in The Government Contractor, C&M attorneys outline the origins of extrapolation, examine the divergent district court rulings on whether it may be used to prove damages, explain the significance of it to contractors facing FCA liability, and provide practice tips for litigating cases with statistical sampling.
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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
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Gaming Addiction Litigation: Turner v. Epic Games & Roblox and What It Means for the Industry
