False Claims Act Guide

2021 and the road ahead

Our editors

Anthony E. Fuller

Anthony E. Fuller

Partner and Editor
Boston

Gejaa T. Gobena

Gejaa T. Gobena

Partner and Editor
Washington, D.C.

Michele W. Sartori

Michele W. Sartori

Partner and Editor
Washington, D.C.

David I. Sharfstein

David I. Sharfstein

Partner and Editor
Washington, D.C., Baltimore

Executive summary

Executive summary

2021 ushered in a new administration, new U.S. Department of Justice (DOJ) officials, and, of course, new DOJ policies and initiatives – many of which implicate the False Claims Act (FCA). But one thing that remained constant was DOJ’s use of the FCA as a key enforcement tool. 

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2021 and the road ahead

2021 and the road ahead

Healthcare digitization creates
new FCA risk

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DOJ intensifies scrutiny of
cybersecurity practices

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Fact-intensive materiality inquiries protract litigation

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Standard for government dismissals remains uncertain

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Safeco, Supervalu, reasonable
interpretations of ambiguous regulations

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Re-evaluating the benefits
of DOJ cooperation

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Looking ahead

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