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The Top FCA Developments of 2021

Client Alert | less than 1 min read | 02.25.22

2021 was another busy year in False Claims Act enforcement and litigation. Significant decisions were issued across the circuits, spanning government dismissal authority, materiality, scienter, Rule 9(b) pleading standards, the Eighth Amendment’s Excessive Fines Clause, and more. The year also saw proposed amendments introduced by Senator Chuck Grassley aimed at strengthening the statute and overruling certain case law developments, as well as a renewed and confirmed focus on COVID-19 funding fraud enforcement and the launch of a new cybersecurity fraud initiative. These highlights are among the important developments discussed by C&M attorneys in a “Feature Comment” published in The Government Contractor.

Insights

Client Alert | 4 min read | 11.09.26

CMS Finalizes Its 2026 Organ Procurement Organization Rule

On November 3, 2026, the Centers for Medicare and Medicaid Services (CMS) finalized a follow-up to its 2020 final rule governing conditions of participation for organ procurement organizations (OPO). CMS’s final rule in 2020 set forth outcome measures for OPOs. The latest final rule further cements the new rating structure that will determine which of the 55 OPOs will be recertified at the end of the current cycle. The final rule largely tracks CMS’s proposed rule, which we discuss here, with the following notable exceptions: ...