February 1, 2018

QUESTION:        I saw in last week’s HLE’s Government at Work that the Department of Justice (“DOJ”) has recently issued a memorandum that discusses the dismissal of a qui tam case.  Can the government really do that?  Can you provide more information?

 

ANSWER:            Yes, the DOJ has the authority to dismiss a qui tam over the objection of the qui tam relator.  On January 10, 2018, the Director of the DOJ’s Commercial Litigation Branch, Fraud Section, issued a Memorandum to the attorneys in that branch of the DOJ entitled “Factors for Evaluating Dismissal Pursuant to 31 U.S.C. 3730(c)(2)(A)” that discusses when it is appropriate for DOJ attorneys to exercise this authority.

In this Memo, the DOJ recognized that while the number of qui tam cases that have been filed over the past several years has exceeded 600 new cases per year, the number of cases in which the DOJ has intervened has remained relatively the same.  The Memo notes that even in cases in which the DOJ declines to intervene, the DOJ expends considerable resources monitoring the case and in some instances must produce discovery or otherwise participate.  The DOJ is also concerned that qui tam cases that lack merit can generate adverse precedent which could hamstring the DOJ’s ability to enforce the False Claims Act.

Therefore, DOJ attorneys have been advised not only to determine whether to intervene in a qui tam case, but to go a step further and, if certain factors are present, to seek the dismissal of the qui tam claim under 31 U.S.C. §3730(c)(2)(A).

The Memo notes that, historically, the DOJ has seldom invoked this authority.  It also advised DOJ attorneys to be judicious in exercising this authority.  However, the Memo then outlines the factors that the DOJ should consider when deciding whether to dismiss a qui tam claim.  Those factors include qui tam claims that:  are meritless; duplicate pre-existing government investigations; threaten to interfere with agency policy or the administration of its programs; threaten the DOJ’s litigation prerogatives; involve intelligence agencies or military procurement; cause the government’s costs to exceed the expected recovery; or frustrate the government’s efforts to conduct a proper investigation.

The Memo states that the DOJ should consult closely with the affected agency as to whether dismissal is appropriate, advise the relator of the prospect of dismissal, and give the relator the opportunity to voluntarily dismiss the action.  However, if the qui tam relator does not voluntarily dismiss the action, then if any of the factors described in the Memo exist, the DOJ is to exercise its authority to dismiss the qui tam claim, which should be filed at or near the time that the DOJ declines to intervene in the qui tam case.

Click here if you want to see the entire Memo or, if you prefer, please join HortySpringer partners Henry Casale and Dan Mulholland who will be discussing this Memo and other late-breaking fraud and abuse and compliance developments at our Physician-Hospital Contracts Clinic in Austin on March 1-3, 2018.  Click here to learn more about it and register.

February 2, 2017

QUESTION:        Our hospital just received a Civil Investigative Demand from the Department of Justice.  Should we be worried?

ANSWER:            Yes.  A Civil Investigative Demand (CID) is like a beefed-up subpoena.  While a subpoena duces tecum will only call for production of documents, a CID can require the recipient to produce documents, as well as answer interrogatories or give oral testimony under oath.  Moreover, the authority to issue a CID is quite broad.  The issuing DOJ attorney only needs a “reason to believe that any person may be in possession, custody, or control of documentary material or information relevant to a false claims law investigation.”  The potential breadth of a CID and the ability to compel sworn testimony raise critical issues for recipients, particularly those who may be under a concurrent criminal investigation.  And unlike interrogatories or depositions in a civil case, CIDs are an investigative, not discovery, tool, so only the government gets to use them.

If the CID is overly broad, your attorney may be able to get the DOJ attorney to limit the scope of the CID.  However, the information being demanded should give you an idea of the issue being investigated.  If requested, the government will also usually provide the recipient of a CID with additional time to respond.  Whether the DOJ will pursue the matter further or whether a qui tam has been filed is impossible to ascertain at this stage.  What is required is for you to search your files and work with your attorney to respond to the CID to the best of your ability.