Overview
For The Record
Defended a Pennsylvania-based healthcare provider against federal False Claims Act allegations under 31 U.S.C. § 3729 et seq., resolved through coordinated settlement with the U.S. Attorney's Office. Pennsylvania's distinctive position as one of the few states without a state-level FCA shaped the procedural posture, with enforcement operating exclusively through the federal framework. The settlement preserved the client's Medicaid provider status and established a clean resolution path for similar matters under federal FCA enforcement in Pennsylvania.
Federal FCA Framework and Pennsylvania Context
Pennsylvania is one of the few US states without a state-level False Claims Act. Federal FCA enforcement under 31 U.S.C. § 3729 et seq. therefore proceeds without parallel state-level claims for healthcare fraud allegations involving Pennsylvania state-funded programs. The framework includes the federal treble damages and per-claim civil penalties, the qui tam (whistleblower) mechanism, and the materiality and falsity standards developed under Escobar v. Universal Health Services.
Investigation and Coordination
The team coordinated an internal investigation in parallel with the federal investigative process, building the factual record on the client's billing practices, certifications, and program participation. Engagement with the U.S. Attorney's Office during the seal period provided structured opportunity to present the investigation findings and substantive defenses. The team's positioning emphasized the documented compliance practices and the materiality framework that controls under Escobar.
Settlement Resolution
The settlement resolved the federal FCA action through coordinated negotiation with the U.S. Attorney's Office. The structure preserved the client's continued participation in Medicaid and other federally funded healthcare programs and avoided the cost, exposure, and reputational impact of contested federal proceedings. The result also produced a clean precedential record for similar matters in Pennsylvania, where the absence of a state FCA framework makes federal resolution dispositive.
Engagement Details
The Matter, Stated Plainly
Every matter carries its own practical shape, distinct from the last. What follows is specific to this engagement, not a benchmark for what another matter might look like.
- Outcome
- settlement
- Resolution
- Resolved a federal False Claims Act action against a Pennsylvania-based healthcare provider through coordinated settlement with the U.S. Attorney's Office. The matter proceeded entirely under federal FCA jurisdiction under 31 U.S.C. § 3729 et seq., reflecting Pennsylvania's distinctive position as one of the few states without a state-level FCA framework. The settlement preserved the client's Medicaid provider status.
- Geography
- PA, US
- Resolved
- June 13, 2025
- Duration
- 20 months
- Attorneys
- Marcus Cicero
Past results do not guarantee, warrant, or predict a similar outcome in any future matter. Every engagement is unique and must be evaluated on its own facts and circumstances.
Healthcare compliance, examined closely
Discuss a Federal FCA Matter
Federal FCA exposure touches more than the allegation itself: billing systems, program participation, and the daily work of running a healthcare practice. Our False Claims Act Litigation team approaches these matters with the same preparation regardless of how they ultimately resolve. If your organization is navigating a similar inquiry, we welcome the conversation.