No End in Sight: The Long Tail of COVID Relief Fraud Enforcement
Client Alert | 1 min read | 08.15.23
Although the COVID-19 public health declaration officially ended in May, government investigations of pandemic relief fraud are from over. As observed in a recent report by the Small Business Administration Office of Inspector General, investigations will likely ensue for years to come in light of Congress’s decision to extend the statute of limitations to ten years for pandemic relief fraud.
In an Expert Analysis article published in Law360, C&M attorneys analyze recent enforcement trends and discuss practical steps that companies can take to mitigate risks should they find themselves under investigation or a defendant in a False Claims Act suit involving COVID relief loans.
Insights
Client Alert | 5 min read | 05.16.24
CMS Finalizes Contested Rule on Nursing Home Staffing and Facility Assessments
On May 10, 2024, the Centers for Medicare & Medicaid Services (“CMS”) published a Final Rule that, for the first time, imposes national minimum nurse staffing requirements for nursing homes. Specifically, the standard adopted by CMS requires minimum staffing of 3.48 hours per resident day (“HPRD”), as discussed in more detail below. CMS estimates that the new requirements will cost facilities $43 billion over the next 10 years, which is more than the $40.6 billion cost that CMS estimated for Proposed Rule of 3.0 HPRD. Some industry sources estimate that less than 25% of nursing facilities across the country currently meet the full scope of staffing standards laid out in CMS’ Final Rule due to a myriad of factors including labor shortages and increasing wage pressures. Indeed, the impact and cost of these staffing requirements will vary significantly by state. For example, CMS reported that at least one state will need to increase certain staff by nearly 96% to meet the minimum standards, while other states already meet the requirements.
Client Alert | 3 min read | 05.15.24
Client Alert | 3 min read | 05.14.24
Client Alert | 4 min read | 05.13.24
Harmonizing AI with EEO Requirements: OFCCP’s Blueprint for Federal Contractors
