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Rise in Reverse FCA Cases Amidst ‘America First’ Trade Policies

Client Alert | 1 min read | 04.25.19

On March 27, 2019, the U.S. Department of Justice intervened in United States ex rel Vale v. Selective Marketplace Ltd., a False Claims Act (FCA) suit brought against a clothing importer for allegedly evading customs duties. The suit is the latest example in a growing number of FCA actions brought against importers for allegedly concealing obligations to pay duties to U.S. Customs and Border Protection. The rise in qui tam suits based on avoidance of duties, combined with the administration’s protectionist policies, means that importers could face increased FCA risks for years to come. In an Expert Analysis article published in Law360, C&M attorneys analyze recent enforcement trends and discuss practical steps that importers can take to mitigate risks.

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Client Alert | 8 min read | 12.20.24

End of Year Regulations on Interoperability

Federal policy efforts to advance health data exchange and interoperability are continuing to change rapidly. The latest changes are the publication of two final rules by the Assistant Secretary for Technology Policy/Office of the National Coordinator for Health Information Technology (ASTP/ONC) finalizing parts of the of the Health Data, Technology, and Interoperability (HTI-2) Proposed Rule. These rules adopt requirements regarding the Trusted Exchange Framework and Common Agreement (TEFCA) (HTI-2 Part 1), and create a new Information Blocking exception under Protecting Care Access (HTI-2 Part 2), on December 16th and 17th, respectively....