The Top FCA Developments Of 2018
Client Alert | less than 1 min read | 02.04.19
From the government’s renewed use of its dismissal authority to changes to the policy on corporate cooperation credit, the second year of False Claims Act (FCA) enforcement under the Trump administration was defined by several announcements concerning how the Department of Justice (DOJ) will pursue cases under the FCA. These policy reforms are among the many FCA developments highlighted by C&M attorneys in a "Feature Comment" published in The Government Contractor, which considers key issues such as small business fraud, materiality post-Escobar, trade and domestic preferences, and the Supreme Court’s review of a circuit split concerning the statute of limitations.
Contacts
Insights
Client Alert | 5 min read | 08.21.26
FTC Proposes Enforcement Policy Statement on Personalized Pricing: What Businesses Need to Know
On August 19, 2026, the Federal Trade Commission (FTC) announced a proposed Enforcement Policy Statement on personalized pricing — the practice of companies using consumers’ personal data to set individualized prices, discounts, coupons, or other incentives. The proposed statement, which is open for public comment for 30 days following publication in the Federal Register, marks a major step up in the FTC’s focus on data-driven pricing strategies and puts businesses across industries on notice that undisclosed or inadequately disclosed personalized pricing will not be tolerated. Importantly, while the proposed statement is not a binding legal requirement and does not create new legal obligations, it serves as an enforcement warning that the FTC is prepared to use its existing enforcement authority under Section 5 of the FTC Act (Section 5) and is also a potential harbinger of rulemaking. Businesses that engage in — or are considering — personalized pricing should carefully assess their disclosure practices and data collection procedures against the standards articulated in this statement.
Client Alert | 7 min read | 08.19.26
CMS’s Final Rule Bans Federal Medicaid Funding for Youth Gender-Affirming Care
Client Alert | 2 min read | 08.19.26
Client Alert | 7 min read | 08.17.26
Delayed Notification of Cyberattacks May Trigger HIPAA Breach Notification Rule
