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Quick Answer

What Is False Claims Act?

The False Claims Act (31 USC 3729-3733) is a federal law imposing civil liability on any person who knowingly submits, or causes to be submitted, a false or fraudulent claim for payment to the U.S. government, with treble damages plus per-claim civil penalties.

Compliance

False Claims Act

Also known as: FCA; 31 USC 3729-3733; Lincoln Law

The False Claims Act (31 USC 3729-3733) is a federal law imposing civil liability on any person who knowingly submits, or causes to be submitted, a false or fraudulent claim for payment to the U.S. government, with treble damages plus per-claim civil penalties.

Definition

The FCA imposes liability on persons who knowingly present false claims, make false records material to a false claim, or knowingly conceal an obligation to pay the government. 'Knowingly' includes actual knowledge, deliberate ignorance, and reckless disregard. The statute permits qui tam suits where private whistleblowers (relators) sue on behalf of the government and receive 15-30% of recoveries. Per-claim penalties range from approximately $13,946 to $27,894 (2024 inflation-adjusted) plus treble damages. Healthcare accounts for the largest share of DOJ FCA recoveries — $2.68 billion of the $2.91 billion total in FY 2023.

Example

Submitting Medicare claims for E/M services at a higher level than documentation supports (upcoding), billing for services not rendered, billing duplicate claims, or unbundling services that should be billed together can each constitute FCA violations. Knowingly retaining a Medicare overpayment beyond 60 days after identification (the '60-day rule' under the ACA) is also an FCA violation.

Common Misconceptions

The FCA does not require intent to defraud — reckless disregard or deliberate ignorance is enough. A 'mistake' is no defense if the practice failed to implement reasonable compliance controls. AKS violations are per se FCA violations under the 2010 ACA amendment, meaning kickback-tainted claims are automatically false claims.

Practical Application

Billing companies and practices should maintain a documented compliance program with regular coding audits, a confidential reporting channel for staff concerns, prompt investigation of identified overpayments, and timely refund of identified overpayments within the 60-day window to avoid FCA exposure.

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