Practice Area

Healthcare Fraud Defense

Healthcare fraud enforcement has become one of the highest priorities in federal practice — and one of the most complex. Civil False Claims Act cases, qui tam relator suits, criminal indictments under the Anti-Kickback Statute, HHS-OIG and CMS investigations, and parallel state Medicaid Fraud Control Unit matters frequently overlap on a single set of facts. The firm represents providers, executives, and companies across that full landscape.

Defending providers, executives, and companies

Healthcare fraud cases turn on detail — coding rules, billing conventions, medical necessity, fair market value, the structure of referral relationships. The firm brings the legal experience of a long career at the U.S. Attorney’s Office together with the discipline to learn each client’s clinical and operational realities thoroughly.

Matters the firm handles

  • False Claims Act (FCA) — civil and criminal, including qui tam relator suits
  • Anti-Kickback Statute (42 U.S.C. § 1320a-7b) — criminal and civil
  • Stark Law (Physician Self-Referral Law) — disclosures and enforcement
  • HHS-OIG and CMS investigations, audits, and exclusion proceedings
  • Department of Justice civil fraud and Healthcare Fraud Strike Force matters
  • Medicare and Medicaid billing fraud and overpayment investigations
  • DEA registration investigations and Controlled Substances Act matters
  • State Medicaid Fraud Control Unit (MFCU) investigations and prosecutions
  • Hospice, home health, and durable medical equipment (DME) investigations

Early-stage representation

Healthcare cases often surface through a CID, a contractor audit, an HHS-OIG subpoena, or notice of a sealed qui tam complaint. The earliest decisions — about preservation, internal review, billing freeze-frames, and communication with relators — frequently shape resolution.

Internal review and remediation

A privileged internal review of the relevant billing, coding, and referral arrangements can identify real exposure, separate that from non-issues, and lay the foundation for credible remediation and defense.

Engagement with the government

Productive engagement with line AUSAs, OIG agents, and contractor reviewers — presenting the clinical, operational, and legal context they often lack — can change the trajectory of a case before formal charges or complaints arrive.

Resolution

Where matters must resolve, the firm negotiates declinations, civil FCA settlements, corporate integrity agreements, deferred-prosecution and non-prosecution agreements, and (where necessary) plea or trial dispositions — with full attention to collateral consequences such as exclusion.

When to bring the firm in

The firm is most useful early. Some signals to call:

  • An HHS-OIG subpoena or CID has been received
  • Notice of a sealed qui tam complaint or a relator’s identity has surfaced
  • A contractor audit (ZPIC, UPIC, RAC, MAC) is escalating
  • Federal agents have appeared at a clinic, hospital, or executive’s home
  • Medicare or Medicaid payments have been suspended
  • Exclusion under 42 U.S.C. § 1320a-7 has been proposed

Why clients choose Fernald Advisory

Federal healthcare-fraud experience

Federal experience supervising and prosecuting complex healthcare fraud cases — and now defending them — provides a working understanding of what the government looks for and where defenses are real.

Comfort with clinical and billing complexity

Healthcare fraud cases turn on details only specialists usually see. The firm puts in the work to learn them.

Coordination with civil and regulatory counsel

Most healthcare cases require coordinating with civil, regulatory, compliance, and licensing counsel. The firm leads that coordination rather than working around it.

Frequently Asked

What clients often ask

What is the False Claims Act?

The False Claims Act (31 U.S.C. §§ 3729-3733) imposes civil liability on anyone who knowingly submits false claims to the federal government. In healthcare, that often means Medicare or Medicaid claims. Qui tam provisions let private ‘relators’ sue on the government’s behalf and share in recoveries, which has driven much of the modern enforcement landscape.

What is a qui tam case?

A qui tam case is a False Claims Act lawsuit filed under seal by a private relator (often a former employee). The government investigates while the case remains sealed — typically for many months — and then decides whether to intervene. The defendant frequently does not know the case exists until the government’s investigation is well underway.

What is the Anti-Kickback Statute?

The Anti-Kickback Statute (42 U.S.C. § 1320a-7b) is a criminal statute prohibiting the knowing exchange of remuneration to induce or reward referrals of items or services payable by a federal healthcare program. Violations can trigger criminal charges, civil False Claims Act liability, and exclusion.

Can I be excluded from Medicare and Medicaid?

Yes. Exclusion under 42 U.S.C. § 1320a-7 is one of the most serious collateral consequences of healthcare fraud matters. Avoiding or shaping the scope of exclusion is often a central goal of resolution. The firm addresses exclusion exposure from the first conversation.

Discuss a federal matter

Confidential consultations with Michelle Fernald. Serving Austin, San Antonio, Dallas, Houston, El Paso, and federal courts nationally.

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