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Counting FCA Penalties: It's All In The Claims


In this article, Members Adam Feinberg and Brian Hill and Counsel Jonathan Kossak* discuss the recent increase in the civil penalties available under the False Claims Act (FCA). The authors describe how the increased penalty amount will place renewed focus on the proper method for counting the number of penalties. "This is particularly true in the health care field and other industries where companies regularly submit thousands of claims for reimbursement and are at risk of being liable for substantial FCA penalties," the authors said.

*Former Miller & Chevalier attorney