Seth and Danielle noted that a number of the settlements “are consistent with trends we have seen over the past year” and “relate in part to medical necessity and commission-based payments to independent contractors. Other settlements “have emphasized the benefits of self-disclosure and include a rarer case of a violation of the Stark law in the laboratory context.” Three of the settlements highlighted “a growing trend of cases filed by non-traditional whistleblowers, such as insurance carriers, activists, investors, and special purpose entities created solely to file litigation. Seth and Danielle also highlight a qui tam case brought by an insurance carrier whistleblower and explain that non-traditional relators may bring False Claims Act claims “for different reasons than traditional relators, such as former or current employees … bringing FCA claims may be an effort to deter bad actors that conduct business with the relator, to advance a policy interest, or simply to recoup reimbursements for unnecessary testing…a reminder that fraud can be alleged by both corporate insiders and outsiders.” Read the article.