Rejecting Expansive FCA False Certification Theory
In United States ex rel. Conner v. Salina Regional Health Center, Inc., ___ F.3d ___, 2008 WL 4430668 (10th Cir. Oct. 2, 2008), the Tenth Circuit held that an allegedly false certification on a hospital's Medicare cost report does not automatically render false all claims submitted by that provider.
Instead, the court imposed a materiality requirement...
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