A recent holding by the Eighth Circuit Court of Appeals in United States ex rel. Cairns v. D.S. Med., LLC took a stance on the causation standard for False Claims Act (FCA) cases premised on violations of the Anti-Kickback Statute (AKS) and may provide defendants in those cases with the ability to raise a valid
Rachel A. Frost
Associate, Litigation and Healthcare Departments
Ms. Frost concentrates her practice in the areas of commercial and healthcare litigation, criminal defense, internal investigations, and regulatory compliance. She assists in the representation of numerous public and private business entities, private individuals, elected officials and candidates for public office. Ms. Frost’s experience includes drafting discovery requests and responses, various pre-trial motions, briefs and other legal documents, researching complex legal issues, and attending depositions and pre-trial conferences.
Ms. Frost has prior experience in the practice areas of real estate and corporate transactions, redevelopment and land use, financial development and economic incentives, and related litigation.
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DOJ Announces COVID-19 Fraud Strike Force Teams; Targets PPP Lender as Government Enforcement Actions Continue to Escalate
More than a year has passed since U.S. Attorney General Merrick B. Garland established the COVID-19 Fraud Enforcement Task Force to utilize the resources of the U.S. Department of Justice (DOJ) and partner with various governmental agencies to combat COVID-19-related fraud. Since that time, the DOJ has touted its enforcement efforts in both the civil…
New Implementation Requirements for Cures Act Final Rule Become Effective This Fall
In 2016, Congress passed the 21st Century Cures Act to drive the electronic access, exchange, and use of health information. On March 9, 2020, the U.S. Department of Health and Human Services (HHS) Office of the National Coordinator for Health IT (ONC) released its Final Rule, which established exceptions to the Act’s information blocking provision…
An Update on DOJ Enforcement Actions Alleging PPP Loan and Healthcare-Related COVID-19 Fraud
The COVID-19 Fraud Enforcement Task Force was established in May 2021 to utilize the resources of the U.S. Department of Justice (DOJ) and various governmental agencies to combat COVID-19-related fraud. These efforts have led to investigations and prosecutions involving Paycheck Protection Program (PPP) fraud as well as healthcare-related COVID-19 fraud, the extent, and implications of…