Olson v. Fairview Health Servs. of Minn. — Aug. 2016 (Summary)

QUI TAM

Olson v. Fairview Health Servs. of Minn.
No. 15-1780 (8th Cir. Aug. 8, 2016)

The United States Court of Appeals for the Eighth Circuit affirmed a district court’s grant of a motion to dismiss in favor of a defendant medical center against a relator, who brought a qui tam action alleging violations of the False Claims Act (“FCA”).

The relator alleged that the medical center fraudulently induced the Minnesota Department of Human Services to over-reimburse it for services provided to Medical Assistance patients by claiming that the children’s unit of the medical center was a children’s hospital under an amendment that excluded children’s hospitals from a reimbursement reduction.  The relator maintained that the medical center knowingly presented or caused to be presented false or fraudulent claims for payment or approval of Medicaid monies, knowing that it did not legally qualify for the exemption.

The court was unpersuaded by the relator’s argument, reasoning that the relator assumed that the term “children’s hospital” is simply a derivative of combining the definition of “children” and “hospital.”  The court found that there was no statutory definition, and that in the absence of an explicit statutory definition of “children’s hospital,” the statute was ambiguous, and a reasonable interpretation of ambiguous statutory language does not give rise to an FCA claim.  Therefore, the court affirmed the judgment of the district court.