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The Top FCA Developments Of 2017

Client Alert | less than 1 min read | 02.02.18

From decisions on small business fraud to interpretations of the reverse FCA, 2017 was another busy year for False Claims Act developments.  In a "Feature Comment" published in The Government Contractor, C&M attorneys highlight top developments from 2017 on key issues such as original source requirements, DOJ’s potential dismissal of meritless qui tams, statistical sampling, and perhaps most significantly, the continued evolution of the case law in the wake of the Supreme Court’s landmark implied certification and materiality decision in Escobar

Insights

Client Alert | 7 min read | 08.17.26

Delayed Notification of Cyberattacks May Trigger HIPAA Breach Notification Rule

After identifying a ransomware attack in 2021, OSF Healthcare System waited until its forensic investigation had concluded before notifying the U.S. Department of Health and Human Services (HHS) — and the affected individuals — of the breach. The 110-day delay (nearly double the 60-calendar-day notification deadline mandated by the HIPAA Breach Notification Rule) triggered an investigation from HHS’s Office for Civil Rights (OCR). The health system’s investigation determined that protected health information (PHI) had been stolen....