False Claims Act Playbook

On July 20, 2022, the Office of Inspector General (“OIG”) for the Department of Health and Human Services issued a Special Fraud Alert (the “Alert”) on potential fraud schemes involving companies that provide telehealth, telemedicine, or telemarketing services (referred to collectively in the Alert as “Telemedicine Companies”).[1]

Historically, if the Securities and Exchange Commission (“SEC”) wanted to obtain monetary relief against a defendant for violations of the federal securities laws, it needed to sue that defendant in federal court.  However, when Congress passed the Sarbanes-Oxley Act in 2002, it gave the SEC the option of seeking such relief from its own administrative law judges, instead.