Author: Mara Sanders

Mara regularly advises clients on matters of state and federal regulatory compliance, investigations, and enforcement, including with respect to health care fraud and abuse laws, such as the Stark Law and Anti-Kickback Statute, clinical research compliance and ethics, and liability under the False Claims Act. Mara also advises clients on matters related to the Medicare and Medicaid programs, state and federal privacy & security laws, scope of practice and licensure, and federal grant funding. Mara’s pro bono work includes representing asylum seekers and advising not-for-profit health care and public health organizations.

Proposed CMS Rule Ramps Up Potential Medicare Fraud Administrative Remedies

On July 6, 2026, the Centers for Medicare & Medicaid Services (“CMS”) proposed a rule that would expand its administrative remedies to combat potential fraud. The proposed rule is the latest in a round of administrative actions that signal CMS’s intent to aggressively pursue allegations of Medicare and Medicaid fraud and heighten the risk of fraud enforcement...

The False Claims Act and the Anti-Kickback Statute: Causation, Materiality, and the Connection Between the Two

Violations of the federal Anti-Kickback Statute (the “AKS”)[1] have long served as a basis for liability under the federal False Claims Act (the “FCA”).[2]  Recently, however, there has been increasing uncertainty regarding how far a violation of the AKS sweeps to render claims “false” under the FCA.  Courts are currently at odds with each other...