Just When You Thought It Was Over: Eleventh Circuit Deepens Disagreement on FCA's Tolling Provision
Client Alert | 1 min read | 06.13.18
In U.S. ex rel. Hunt v. Cochise Consultancy Inc., the Eleventh Circuit held that a relator in a non-intervened qui tam action may rely on the FCA’s tolling provision in 31 U.SC. § 3731(b)(2), which expands the 6-year statute of limitations to allow suits to be brought within 3 years of the date that the relevant government official learns of the alleged violation. In so holding, the court disagreed with already divergent views from the Fourth, Tenth, and Ninth Circuits, increasing the depth of the circuit split on this issue. C&M attorneys discuss the Eleventh Circuit’s decision and its potential impact in a recent post for Crowell & Moring’s Government Contracts Legal Forum.
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Client Alert | 7 min read | 11.02.26
DOL Finalizes PBM Fee Disclosure Requirements
On October 29, 2026, the U.S. Department of Labor’s (DOL) Employee Benefits Security Administration (EBSA) issued a 350-page final rule requiring providers of pharmacy benefit management services and their affiliated brokers and consultants to disclose fees and compensation received to fiduciaries of covered large, self-insured ERISA group health plans. According to DOL’s accompanying fact sheet, the disclosures will give employers more visibility into the payments PBMs may receive from various sources and help fiduciaries evaluate and monitor arrangements over time.
Client Alert | 4 min read | 10.30.26
Client Alert | 3 min read | 10.29.26
What University Licensors Should Learn From TexasLDPC v. Broadcom
