Articles and Blogs

condition of participation

CMS Proposes New Rules Blocking Funding to Providers of Gender-Affirming Care to Minors

[12/19/25]

Posted on December 19, 2025 in Health Law News

Published by: Hall Render

On December 18, 2025, the Centers for Medicare & Medicaid Services (“CMS”) issued two proposed rules aimed at limiting provision of gender-affirming care to minors (each a “Proposed Rule” and, collectively, the “Proposed Rules”). The first rule would add a new Condition of Participation (“CoP”), prohibiting a hospital from performing “sex-rejecting procedures” on minors, in... READ MORE

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Relator’s Damages and Documentation Theories Rejected in Halifax

[07/04/14]

Posted on July 4, 2014 in False Claims Act Defense

Written by: Drew B. Howk

This week a Court in the Middle District of Florida dealt a blow to a whistleblower’s allegations of fraud in U.S. ex rel. Baklid-Kunz v. Halifax Hospital Medical Center ruling that: (1) the Relator is barred from recovering damages even if it can prove its allegations and (2) the Relator is barred from arguing or... READ MORE

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Sixth Circuit: Violations of Conditions of Participation Insufficient Basis for FCA Claims

[04/02/13]

Posted on April 2, 2013 in False Claims Act Defense

Written by: David B. Honig and Andrew B. Howk

By David B. Honig and Andrew B. Howk In U.S. v. MedQuest, the Sixth Circuit held that violations by a provider of conditions of participation in Medicare were insufficient as a matter of law to “trigger the hefty fines and penalties created by the FCA.” This case was a reaffirmation by the Sixth Circuit... READ MORE

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