Topic Archives: Health Care

Trade Agreements Act Compliance: Federal Circuit Clarifies Country of Origin and Place of Manufacture Analyses

A variety of arcane domestic-preference regimes apply to many Federal procurements – the Buy American Act (BAA), the Trade Agreements Act (TAA), the Berry Amendment, and the Cargo Preference Act, to name a few.  In Acetris Health, LLC v. United States, the Court of Appeals for the Federal Circuit recently denied a Government appeal and ...›

FCA
November 29, 2016False Claims Act, Health Care

Tenet Case Signals Shift In Health Care Fraud Enforcement

Historically, the federal government has fought corporate healthcare fraud in two ways. First, the Department of Justice (“DOJ”) routinely intervenes in civil False Claims Act (“FCA”) cases filed by qui tam relators.  Second, the federal government typically has relied on individual U.S. Attorney’s Offices to initiate and prosecute criminal healthcare fraud cases.  Although DOJ relied ...›

small business
July 20, 2016Health Care, Small Business

GSA Guidance Post-Kingdomware: The “Rule of Two” Does Not Apply To All Federal Supply Schedule Task and Delivery Orders

In a recent article, we speculated that Kingdomware Techs., Inc. v. United States would have broader implications for small business set-aside requirements under General Services Administration (GSA) Federal Supply Schedules (FSS). The article highlights the split between the Kingdomware decision and GSA’s longstanding position that ...›

Small Business
July 13, 2016Health Care, Small Business

Kingdomware: Broader Than SCOTUS Intended?

In a unanimous opinion overturning the U.S. Court of Appeals for the Federal Circuit, the U.S. Supreme Court held that the Department of Veterans Affairs (VA) must consider whether two veteran-owned small businesses (VOSBs) can perform a proposed contract before issuing a solicitation. ...›