Articles and Blogs

Code of Federal Regulations

Here Be Dragons – Regulatory Law and the Advice-of-Counsel Defense

[07/20/12]

Posted on July 20, 2012 in False Claims Act Defense, Litigation Analysis

Written 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 as a roadmap, providing guideposts and requirements for dealing... READ MORE

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A Twenty Year Statute of Limitations?

[03/15/12]

Posted on March 15, 2012 in False Claims Act Defense

Written by: David B. Honig

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. READ MORE

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