Wartime Suspension of Limitations Act Available to Qui Tam Relators Even When the U.S. Does Not Intervene
Client Alert | 1 min read | 03.20.13
In U.S. ex rel. Carter v. Halliburton Co. (Mar. 18, 2013), the Fourth Circuit held that (1) dismissals of a qui tam plaintiff's FCA complaint under the first-to-file bar should be without prejudice, thereby allowing a relator to refile her complaint after the original action has been dismissed and is no longer "pending"; and (2) the Wartime Suspension of Limitations Act (WSLA), which tolls "any statute of limitations applicable to any offense[ ] involving fraud or attempted fraud against the United States" "[w]hen the United States is at war," applies (i) to both civil and criminal fraud against the United States, (ii) even without a formal declaration of war, and (iii) regardless of whether the U.S. intervenes. In a partial dissent, Judge Agee argued that allowing relators to benefit from the WSLA when the government has not intervened provides a "strong financial incentive for relators to allow false claims to build up over time before they filed, thereby increasing their own potential recovery."
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Client Alert | 4 min read | 04.10.26
CMS Finalizes Rate Notice for Medicare Parts C and D (CY 2027)
On April 6, 2026, the Centers for Medicare and Medicaid Services (CMS) circulated the Announcement of Calendar Year (CY) 2027 Medicare Advantage (MA) Capitation Rates and Part C and Part D Payment Policies (the CY 2027 Rate Announcement) to communicate Medicare Advantage (MA) capitation rates and Parts C and D payment policies. The Rate Announcement announces decisions regarding proposals initially published on January 26, 2026, in CMS’s CY 2027 Advance Notice for MA and Part D. The following is a summary of the most significant issues in the Rate Announcement, with further details below:
Client Alert | 2 min read | 04.10.26
Client Alert | 4 min read | 04.10.26
FTC Issues Five-Year Strategic Plan: What Businesses Need to Know
Client Alert | 4 min read | 04.09.26

