Government Program Fraud, False Claims Act & Qui Tam Litigation Playbook

On August 30, 2021, the U.S. Department of Justice (DOJ) announced that Sutter Health and several affiliates, including the Palo Alto Medical Foundation, agreed to pay $90 million to resolve claims that they violated the False Claims Act (FCA) by knowingly submitting inaccurate and unsupported information about the health status of individuals enrolled in Medicare Advantage (or Medicare “Part C”) plans in order to increase payments to Medicare Advantage Organizations with which they contracted, and ultimately themselves.