Ellen Persons

Key Takeaways: Sixth Circuit FCA precedent remains intact. The Sixth Circuit declined to entertain constitutional challenges to the FCA’s qui tam provisions, emphasizing that binding circuit precedent forecloses arguments...more Key Takeaways - New Fraud Division: The White House announced the creation of a new DOJ Division for National Fraud Enforcement, signaling a more coordinated, nationwide approach to civil and criminal fraud investigations and...more Key Takeaways - Reliance on Physician Orders: Clinical laboratories may generally rely on physician orders to establish medical necessity and are not required to independently reassess clinical judgment....more Key Takeaways: Eleventh Circuit Hears Landmark Qui Tam Appeal: The Eleventh Circuit heard oral argument in United States ex rel. Zafirov, an appeal from a district court decision holding the FCA’s qui tam provisions...more