Invoicing Tips To Help Gov't Contractors Avoid FCA Liability

Law360 (July 16, 2020, 5:22 PM EDT) -- The U.S. Court of Appeals for the Eleventh Circuit showed us recently just how challenging it can be for courts within the same judicial circuit to analyze the interplay between False Claims Act materiality and the so-called specific misrepresentations that may appear on invoices that are sufficient to trigger FCA liability.

Making matters more challenging for government contractors, many recent FCA decisions arose in the health care context, meaning direct analogy to government contracts is difficult.

This article will discuss the Angela Ruckh v. Salus Rehabilitation LLC case[1] and its place in the case law interpreting specific misrepresentations, and offer commonsense...

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