by David B. Honig Federal regulations are an enormous morass of complex, confusing, and often contradictory rules. The 2009 Code of Federal Regulations was 163,333 pages in 226 individual books. The 2010 Federal Register, which contains new regulations proposed rules, and presidential papers, contained an additional 81,305 pages. Intended... Continue Reading →Tags: Advice of Counsel, attorney-client privilege, CFR, Code of Federal Regulations, False Claims Act, Federal Register, knowledge, mens rea, Regulations, waiver
Last month the Centers for Medicare & Medicaid Services (CMS) published proposed rules for reporting of overpayments. These proposed rules, if adopted and strictly interpreted, could effectively create a twenty-year statute of limitations under the False Claims Act.... Continue Reading →Tags: 60 day, Centers for Medicare and Medicaid Services, CFR, CMS, CMS–6037–P, Code of Federal Regulations, False Claims Act, FCA, identification, overpayment, proposed rule, regulation, sixty day, statute of limitations, ten years