W. Barron A. Avery

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No Longer Implied: Supreme Court Expressly Recognizes Implied Certification as a Theory of Liability Under the False Claims Act

Photo of W. Barron A. AveryBy W. Barron A. Avery, B. Scott McBride and John W. Petrelli on Posted in Uncategorized
Court Rejects the First Circuit’s “Expansive View” of the Theory by Articulating “Rigorous” Standards of Materiality Yesterday, the U.S. Supreme Court issued a long-anticipated decision on the viability of the “implied certification” theory of liability under the False Claims Act (FCA). In Universal Health Services, Inc. v. United States ex rel. Escobar, a unanimous Court … Continue Reading

Federal Healthcare Contractors Must Comply With Basic Information Security Safeguards

Photo of W. Barron A. AveryBy W. Barron A. Avery on Posted in Uncategorized
In light of the uncertainty generated in the healthcare industry by recent decisions of the OFCCP regarding which entities qualify as federal contractors and subcontractors, this article explains which types of healthcare providers may be affected by the Final Rule. On May 16, 2016, the Department of Defense (DoD), General Services Administration (GSA) and National … Continue Reading
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