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The Global Investigations Review Guide to Compliance

Client Alert | 1 min read | 08.12.24

As the primary civil enforcement statute for investigating and remedying fraud in connection with United States government programs, the False Claims Act (FCA) has resulted in more than $75 billion in recoveries of government funds since 1986. The FCA imposes liability on any person or entity that knowingly submits false claims or certifications to the government or improperly retains money owed to the U.S. government.

In this first-ever chapter on the False Claims Act published by the Global Investigations Review Guide to Compliance, Crowell attorneys provide an informed practical explanation of the requirements of the FCA for both U.S. and international companies and institutions. The chapter describes issues that arise in the investigation and litigation process, as well as common theories of liability in two industries that continue to be targets for FCA actions: government contracts and healthcare.

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....