The Centers for Medicare & Medicaid Services (CMS) recently released data on its 2024 settlements of voluntary self-disclosures related to past violations or potential violations of the physician self-referral law (the Stark Law). In 2024, CMS settled an agency record 314 self-disclosures (an amount that the following chart shows towering over other years), with settlement amounts totaling over $24,700,000 in the aggregate.

The Financial Crimes Enforcement Network (FinCEN) published new guidance on Feb. 27, 2025, putting its plan to begin enforcing the Corporate Transparency Act (CTA) on hold. After the Feb. 17 order by the U.S. District Court for the Eastern District of Texas in Smith v. United States Department of Treasury made the CTA once again enforceable, FinCEN set a deadline of March 21 for reporting companies to submit beneficial ownership information.

Healthcare data pioneer Rebecca Springer visits The Corner Series as a newly minted director at healthcare investment banking boutique Bailey & Co. With McGuireWoods partner and host Geoff Cockrell, Rebecca details the growing governance, risk and compliance (GRC) market in healthcare.

She describes the four “buckets” of GRC — provider data; workforce; safety,…

On January 23, 2025, the United States Court of Appeals for the Fourth Circuit rejected a challenge to Advisory Opinion 22-19 (the “Advisory Opinion”) issued by the United States Department of Health and Human Services, Office of Inspector General (“OIG”). The case, Pharmaceutical Coalition for Patient Access v. United States, centered on whether the Advisory Opinion was appropriate when it found a proposed patient assistance program for Medicare Part D beneficiaries by the Pharmaceutical Coalition for Patient Access (the “Coalition”) could violate the Anti-Kickback Statute (“AKS”). In rejecting this challenge to the Advisory Opinion, the Fourth Circuit signaled the judiciary’s continued respect afforded to government agencies, including OIG’s issuing of advisory opinions, even in a post-Chevron world.

On February 20, 2025, during a speech to the Federal Bar Association’s annual qui tam conference, Michael Granston, Deputy Assistant Attorney General for the Commercial Litigation Branch at the U.S. Department of Justice (DOJ), said that the Trump Administration will seek to “aggressively” enforce the False Claims Act (FCA). In particular, Granston stated that active FCA enforcement is consistent with the Trump Administration’s priorities of increasing government efficiency and “rooting out waste, fraud and abuse.”  

In United States ex rel. Feliciano v. Ardoin, the D.C. Circuit joined every other circuit to consider the issue, holding that a pro se litigant cannot bring a False Claims Act (FCA) case. The court’s reasoning was straightforward: FCA claims belong to the government, not the relator. While individuals may represent themselves in legal matters, they cannot represent another party—including the United States—without being a licensed attorney. The FCA does not provide an exception to this rule, leading the court to affirm the district court’s dismissal as pro se FCA cases cannot proceed.