Whistleblower Cases an Overview

Size: px
Start display at page:

Download "Whistleblower Cases an Overview"

Transcription

1 Whistleblower Cases an Overview by John P. Leader, Esq. 1 1 John is a former Assistant United States Attorney, where he practiced for nine (9) years in the Criminal Division of the Arizona Office.

2 Page 2 What is a whistleblower case? A whistleblower or qui tam action is one filed by a person with information that a corporation or person has committed fraud against a government entity. These laws are designed to help discover and penalize such fraud. They encourage people who know about such fraud to report it and the whistleblower statutes offer significant rewards, to maximize reporting of fraud. There are federal and state whistleblower laws. The federal whistleblower statutes, known as the federal False Claims Act, are codified at 31 U.S.C et. seq. Many, but not all, states have their own whistleblower or qui tam laws. Often, the federal government and state governments work together in investigating whistleblower claims. Whistleblower Procedures Qui tam is Latin for who as well. 2 Whistleblower statutes allow private citizens to bring a lawsuit, on their own behalf and on behalf of a government, against persons or companies believed to be committing fraud against the government entity. The federal false claims procedures are set forth in 31 U.S.C The first step is filing of the qui tam complaint. All False Claims Act complaints are filed under seal. 31 U.S.C. 3732(c). This protects the identity of the whistleblower and minimizes the chances the company or person suspected of committing fraud will learn of the pending action and any possible investigation. The plaintiff in a whistleblower case is called the Relator. Along with filing his or her civil complaint, the Relator prepares the relator s disclosure statement, setting forth the legal and factual bases for the claim. This disclosure statement should and must be is detailed as possible. Both the 2

3 Page 3 complaint and relator s disclosure statement are then served on the United States. The rules for serving the United States are set forth in Rule 5, F.R.Civ.P. If the government is interested in the whistleblower s claim, it will commence its own investigation, with the possibility it will later intervene or join the case. In these cases, intervention on behalf of the government is key. If and when the government decides to intervene, the chances of a successful resolution increase substantially. Many times, the government will neither intervene nor even commence an investigation. If the government does not intervene, the individual whistleblower may still proceed on his or her own, and the government may later decide to intervene. It is much more difficult to prevail, however, if the government doesn t intervene. A federal False Claims Act complaint can be filed in any federal district where any one defendant can be found, resides, transacts business, or in which any act proscribed by section 3729 occurred. This is a fairly broad provision, and those wishing to file federal whistleblower complaints will generally have different venues (i.e., federal districts) in which they can file. Who is the Relator? Typically, the Relator (the client) is an employee or former employee of a company that is committing fraud against the government. Often, the Relator will first try to remedy the misconduct through internal company channels. When that fails, the whistleblower sometimes decides to pursue legal action. A whistleblower or Relator may bring a case even if they had involvement in the wrongdoing. And, the False Claims Act protects those who file qui tam complaints from retaliation (although under Garcetti v. Ceballos, 547 U.S. 410 (2006), government employee whistleblowers may not be protected for disclosures made within the scope of the employee s duties). Other whistleblowers include those doing business with or business against the company in question. Contractors or subcontractors who learned of the fraud may report it. Or, someone may learn of fraud committed by a competitor. Ultimately, anyone who has reliable non-public information about this type of fraud can be a whistleblower.

4 Page 4 File First The first plaintiff to file takes priority over others, meaning there is a race to the courthouse: If more than one whistleblower complaint is filed regarding the same misconduct, the first will take priority. It s therefore very important, if you are approached by a whistleblower whom you believe has a meritorious claim, to get it filed as quickly as you can. Because qui tam actions are filed under seal, you will have no way of knowing whether other suits have already been filed. How Much Do Relators Get? As mentioned above, the potential recovery for a whistleblower can be significant. Under the False Claims Act, the Relator will receive a reward of 15% to 25% of any recovery obtained against the defendant, in cases where the Government has intervened. If the Government intervenes, there is a very high likelihood that the matter will settle out of court. The Relator s share is slightly higher if the Government does not intervene and the case proceeds.

5 Page 5 Even though filing first is very important, there are often multiple whistleblowers who participate in awards against a single defendant. As an example, in April 2010, the pharmaceutical giant AstraZeneca paid $520 million to settle allegations that they illegally promoted a medication off label. Two Relators shared $45,286, examples come in many forms. There has been extensive recent whistleblower litigation against pharmaceutical companies, based on illegal off label promotion of medications, usually patented medications. The United States Food and Drug Administration (the FDA ) protects the public health by assuring the safety, efficacy and security of human and veterinary drugs (http://www.fda.gov/aboutfda/whatwedo/default.htm). Before drug companies can market and sell drugs in the United States, they must obtain FDA approval. To do that, there s an extensive application and approval process. If the FDA approves a patented medication, it is usually for very specific and limited purposes. Under the Federal Food, Drug and Cosmetic Act (FDCA), 21 U.S.C. 301 et. seq., it is illegal for drug companies to market / promote their drugs for off label uses, that is, non-fda approved uses. This is called off label marketing. The harm to the government is that Medicare and State Medicaid agencies end up covering, that is, paying for, many illegal prescriptions (ones generated from off label marketing). The harm to the public can be even greater, because medications end up being prescribed in patient settings that have not been studied to determine safety and efficacy. 3 April 2010 AstraZeneca/DOJ settlement agreement, III(1)(c).

6 Page 6 As an example, the package insert for Seroquel (a second-generation or atypical antipsychotic belonging to AstraZeneca) warns of a condition known as Tardive dyskinesia. This is a neurologic side effect that can, in some cases, be very severe. The FDA maintains the Adverse Event Reporting System (AERS), part of its post-marketing safety surveillance program for all approved drugs and products. The FDA uses AERS to monitor for new adverse events with marketed products. Over 90% of AERs are submitted by drug companies, as required by federal law. Through a Freedom of Information Act request, I obtained all AERs related to the medication Seroquel. There were 970 involving patients who developed Tardive dyskinesia attributed to Seroquel. According to FDA estimates, more than 90 percent of adverse events go unreported. Bartlett v. Mutual Pharmaceutical Company, Inc., 760 F. Supp.2d 220, 234 (N.H. 2011). Thus, based on 970 reported incidents of Tardive dyskinesia associated with Seroquel, and based on FDA s recognition that this number represents only 10% of the actual incidents, there have probably been close to 10,000 cases of Tardive dyskinesia tied to Seroquel. And, this is just for the side effect of Tardive dyskinesia. Seroquel has been tied to other significant side effects, including diabetes. Though prohibited, off label marketing commonly occurs because the profits pharmaceutical companies make from medications (and particularly, patented medications) are, to quote Buddy the Elf, ginormous. As an example, in the AstraZeneca settlement, the company s gross revenues for Seroquel were $2.76 billion in 2005 (AstraZeneca s Annual Report and Form 20F for 2005). And, according to court documents, sales in 2006 increased by nearly 30%, in large part due to illegal off label promotion. As mentioned above, AstraZeneca agreed to pay $520 million to resolve allegations of illegal off label marketing. Other companies have paid far more. In September, 2009 Eli Lilly and Company pled guilty to criminal charges and agreed to pay $1.415 billion for promoting its drug Zyprexa for uses not approved by the FDA. 4 In November, 2013, Johnson & Johnson agreed to pay $1.391 billion to resolve false claims resulting from its off-label promotion of Risperdal, Invega, Natrecor. In August, 2009, Pfizer agreed to pay over $2 billion to resolve whistleblower claims involving several medications. 5 In January, 2011, GlaxoSmithKline ( GSK ) agreed to pay $3.55 billion. There are numerous others. 6 In the non-pharmaceutical setting, in 2014, Bank of America settled a mortgage fraud whistleblower case for $350 million. 7 A former company executive alleged that the bank defrauded the For a more complete list, see the URL listed in footnote 4. 7

7 Page 7 United States and its government-backed mortgage finance companies (Fannie Mae and Freddie Mac) by selling them loans that weren t as good as the company said they were. In 2014, a Tucson health network settled a whistleblower case which alleged doctors were ordering unnecessary tests and billing Medicare for it. 8 A similar case was settled in Alabama. 9 In 2014, a California cell phone company that had provided cellular service to the United States government settled a whistleblower case. There, the DOJ alleges CA Technologies overcharged agencies by at least $100 million by failing to offer discounts on software licenses and maintenance that were given to other customers. Any time the government is being systematically cheated out of funds, a whistleblower action may be appropriate. 8 b67b6e42336a.html 9

8 Page 8 Parallel state court actions As mentioned above, many states have their own whistleblower/qui tam statutes. After AstraZeneca paid $520 million to the federal government, it paid another $68.5 million to 37 individual states. 10 The following states have their own whistleblower statutes: California, Delaware, Florida, Georgia, Hawaii, Illinois, Indiana, Louisiana, Massachusetts, Michigan, Montana, Nevada, New Hampshire, New Mexico, New York, Oklahoma, Tennessee, Texas, Virginia, Connecticut, Iowa, Colorado, Maryland, Minnesota, North Carolina, New Jersey, Rhode Island, Washington, and Wisconsin. The District of Columbia also has whistleblower/qui tam statutes. In some instances, state court qui tam counts can be included in or added to a federal False Claims Act complaint. Conclusion play a very important societal role. They help root out institutional fraud against the government and taxpayers. Additionally, and perhaps more importantly, they help curb unethical corporate practices that, in addition to taking money from taxpayers, substantially harm the public. If you are approached by a potential whistleblower, take it seriously, because the monetary and societal stakes can be huge. Get the complaint filed as quickly as you can because filing first is important. You will then need to serve the complaint and a detailed Relator s Disclosure Statement on the United States. You should consider including state court qui tam counts in your complaint. If the government investigates your claim, and if it decides to intervene in your case, the chances of a successful outcome are good. 10

Your questions answered

Your questions answered Your questions answered You likely have many questions about the legal process and your individual case. We want you to be fully informed, so we are happy to answer them. If you have questions that are

More information

Public School Teacher Experience Distribution. Public School Teacher Experience Distribution

Public School Teacher Experience Distribution. Public School Teacher Experience Distribution Public School Teacher Experience Distribution Lower Quartile Median Upper Quartile Mode Alabama Percent of Teachers FY Public School Teacher Experience Distribution Lower Quartile Median Upper Quartile

More information

Impacts of Sequestration on the States

Impacts of Sequestration on the States Impacts of Sequestration on the States Alabama Alabama will lose about $230,000 in Justice Assistance Grants that support law STOP Violence Against Women Program: Alabama could lose up to $102,000 in funds

More information

False Claims Act. www.whistleblowerlaws.com. Background

False Claims Act. www.whistleblowerlaws.com. Background False Claims Act Background The False Claims Act was enacted in 1863 by President Abraham Lincoln to help prevent defense contractor fraud during the civil war The False Claims Act allows private citizens

More information

Three-Year Moving Averages by States % Home Internet Access

Three-Year Moving Averages by States % Home Internet Access Three-Year Moving Averages by States % Home Internet Access Alabama Alaska Arizona Arkansas California Colorado Connecticut Delaware Florida Georgia Hawaii Idaho Illinois Indiana Iowa Kansas Kentucky Louisiana

More information

False Claims Laws: What Every Public Contract Manager Needs to Know By Aaron P. Silberman 1

False Claims Laws: What Every Public Contract Manager Needs to Know By Aaron P. Silberman 1 False Claims Laws: What Every Public Contract Manager Needs to Know By Aaron P. Silberman 1 When Do False Claims Laws Apply? The federal False Claims Act (FCA) applies to any requests for payment from

More information

Deficit Reduction Act Employee Information Requirements

Deficit Reduction Act Employee Information Requirements November 9, 2006 Deficit Reduction Act Employee Information Requirements The Deficit Reduction Act ( DRA ) requires states participating in the Medicaid program to amend their State Plans to mandate that

More information

List of State DMV Websites

List of State DMV Websites List of State DMV Websites Alabama Alabama Department of Revenue Motor Vehicle Division http://www.ador.state.al.us/motorvehicle/index.html Alaska Alaska Department of Administration Division of Motor

More information

NON-RESIDENT INDEPENDENT, PUBLIC, AND COMPANY ADJUSTER LICENSING CHECKLIST

NON-RESIDENT INDEPENDENT, PUBLIC, AND COMPANY ADJUSTER LICENSING CHECKLIST NON-RESIDENT INDEPENDENT, PUBLIC, AND COMPANY ADJUSTER LICENSING CHECKLIST ** Utilize this list to determine whether or not a non-resident applicant may waive the Oklahoma examination or become licensed

More information

Workers Compensation State Guidelines & Availability

Workers Compensation State Guidelines & Availability ALABAMA Alabama State Specific Release Form Control\Release Forms_pdf\Alabama 1-2 Weeks ALASKA ARIZONA Arizona State Specific Release Form Control\Release Forms_pdf\Arizona 7-8 Weeks by mail By Mail ARKANSAS

More information

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ) ) ) ) ) ) ) ) ) ) ) ) ) ) CONSENT JUDGMENT

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA ) ) ) ) ) ) ) ) ) ) ) ) ) ) CONSENT JUDGMENT IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA UNITED STATES OF AMERICA, et al., v. Plaintiffs, HSBC NORTH AMERICA HOLDINGS INC., et al., Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) Civil

More information

Chex Systems, Inc. does not currently charge a fee to place, lift or remove a freeze; however, we reserve the right to apply the following fees:

Chex Systems, Inc. does not currently charge a fee to place, lift or remove a freeze; however, we reserve the right to apply the following fees: Chex Systems, Inc. does not currently charge a fee to place, lift or remove a freeze; however, we reserve the right to apply the following fees: Security Freeze Table AA, AP and AE Military addresses*

More information

MAINE (Augusta) Maryland (Annapolis) MICHIGAN (Lansing) MINNESOTA (St. Paul) MISSISSIPPI (Jackson) MISSOURI (Jefferson City) MONTANA (Helena)

MAINE (Augusta) Maryland (Annapolis) MICHIGAN (Lansing) MINNESOTA (St. Paul) MISSISSIPPI (Jackson) MISSOURI (Jefferson City) MONTANA (Helena) HAWAII () IDAHO () Illinois () MAINE () Maryland () MASSACHUSETTS () NEBRASKA () NEVADA (Carson ) NEW HAMPSHIRE () OHIO () OKLAHOMA ( ) OREGON () TEXAS () UTAH ( ) VERMONT () ALABAMA () COLORADO () INDIANA

More information

State-Specific Annuity Suitability Requirements

State-Specific Annuity Suitability Requirements Alabama Alaska Arizona Arkansas California Colorado Connecticut Delaware District of Columbia Effective 10/16/11: Producers holding a life line of authority on or before 10/16/11 who sell or wish to sell

More information

State Attorneys General Investigations Experience

State Attorneys General Investigations Experience State Attorneys General Investigations Experience Individual & Multistate Investigation Experience Multistate Investigation Experience Note: Click state name for experience information troutmansanders.com

More information

Net-Temps Job Distribution Network

Net-Temps Job Distribution Network Net-Temps Job Distribution Network The Net-Temps Job Distribution Network is a group of 25,000 employment-related websites with a local, regional, national, industry and niche focus. Net-Temps customers'

More information

BUSINESS DEVELOPMENT OUTCOMES

BUSINESS DEVELOPMENT OUTCOMES BUSINESS DEVELOPMENT OUTCOMES Small Business Ownership Description Total number of employer firms and self-employment in the state per 100 people in the labor force, 2003. Explanation Business ownership

More information

High Risk Health Pools and Plans by State

High Risk Health Pools and Plans by State High Risk Health Pools and Plans by State State Program Contact Alabama Alabama Health 1-866-833-3375 Insurance Plan 1-334-263-8311 http://www.alseib.org/healthinsurance/ahip/ Alaska Alaska Comprehensive

More information

False Claims Act Regulations by State

False Claims Act Regulations by State False Claims Act Regulations by State Under the False Claims Act, 31 U.S.C. 3729-3733, those who knowingly submit, or cause another person or entity to submit, false claims for payment of The purpose of

More information

Englishinusa.com Positions in MSN under different search terms.

Englishinusa.com Positions in MSN under different search terms. Englishinusa.com Positions in MSN under different search terms. Search Term Position 1 Accent Reduction Programs in USA 1 2 American English for Business Students 1 3 American English for Graduate Students

More information

Licensure Resources by State

Licensure Resources by State Licensure Resources by State Alabama Alabama State Board of Social Work Examiners http://socialwork.alabama.gov/ Alaska Alaska Board of Social Work Examiners http://commerce.state.ak.us/dnn/cbpl/professionallicensing/socialworkexaminers.as

More information

STATE-SPECIFIC ANNUITY SUITABILITY REQUIREMENTS

STATE-SPECIFIC ANNUITY SUITABILITY REQUIREMENTS Alabama Alaska Arizona Arkansas California This jurisdiction has pending annuity training legislation/regulation Annuity Training Requirement Currently Effective Initial 8-Hour Annuity Training Requirement:

More information

2014 INCOME EARNED BY STATE INFORMATION

2014 INCOME EARNED BY STATE INFORMATION BY STATE INFORMATION This information is being provided to assist in your 2014 tax preparations. The information is also mailed to applicable Columbia fund non-corporate shareholders with their year-end

More information

State Tax Information

State Tax Information State Tax Information The information contained in this document is not intended or written as specific legal or tax advice and may not be relied on for purposes of avoiding any state tax penalties. Neither

More information

State Specific Annuity Suitability Requirements updated 10/10/11

State Specific Annuity Suitability Requirements updated 10/10/11 Alabama Alaska Ai Arizona Arkansas California This jurisdiction has pending annuity training legislation/regulation Initial 8 Hour Annuity Training Requirement: Prior to selling annuities in California,

More information

NAIC ANNUITY TRAINING Regulations By State

NAIC ANNUITY TRAINING Regulations By State Select a state below to display the current regulation and requirements, or continue to scroll down. Light grey text signifies states that have not adopted an annuity training program. Alabama Illinois

More information

American C.E. Requirements

American C.E. Requirements American C.E. Requirements Alaska Board of Nursing Two of the following: 30 contact hours 30 hours of professional nursing activities 320 hours of nursing employment Arizona State Board of Nursing Arkansas

More information

Real Progress in Food Code Adoption

Real Progress in Food Code Adoption Real Progress in Food Code Adoption The Association of Food and Drug Officials (AFDO), under contract to the Food and Drug Administration, is gathering data on the progress of FDA Food Code adoptions by

More information

Data show key role for community colleges in 4-year

Data show key role for community colleges in 4-year Page 1 of 7 (https://www.insidehighered.com) Data show key role for community colleges in 4-year degree production Submitted by Doug Lederman on September 10, 2012-3:00am The notion that community colleges

More information

Schedule B DS1 & DS3 Service

Schedule B DS1 & DS3 Service Schedule B DS1 & DS3 Service SCHEDULE B Private Line Data Services DS1 & DS3 Service... 2 DS-1 Local Access Channel... 2 DS-1 Local Access Channel, New Jersey... 2 DS-1 Local Access Channel, Out-of-State...

More information

LABORATORY CORPORATION OF AMERICA HOLDINGS BUSINESS PRACTICES MANUAL

LABORATORY CORPORATION OF AMERICA HOLDINGS BUSINESS PRACTICES MANUAL LABORATORY CORPORATION OF AMERICA HOLDINGS BUSINESS PRACTICES MANUAL Subject: Compliance With False Claims Acts Section: 27.0 Under Federal and State Laws Update: January 2015 Replaces: January 2013 Initiated

More information

REAL ESTATE RELATED ERRORS & OMISSIONS APPLICATION

REAL ESTATE RELATED ERRORS & OMISSIONS APPLICATION Kinsale Insurance Company P. O. Box 17008 Richmond, VA 23226 (804) 289-1300 www.kinsaleins.com REAL ESTATE RELATED ERRORS & OMISSIONS APPLICATION APPLICANT S INFORMATION 1. Legal name of the business who

More information

Current State Regulations

Current State Regulations Current State Regulations Alabama: Enacted in 1996, the state of Alabama requires all licensed massage therapists to * A minimum of 650 classroom hours at an accredited school approved by the state of

More information

Consent to Appointment as Registered Agent

Consent to Appointment as Registered Agent Consent to Appointment as Registered Agent This form is used by the person or business entity that agrees to act as the registered agent for a limited liability company. Every person or business entity

More information

Question by: Karon Beyer. Date: March 28, 2012. [LLC Question] [2012-03-29]

Question by: Karon Beyer. Date: March 28, 2012. [LLC Question] [2012-03-29] Topic: LLC Question Question by: Karon Beyer : Florida Date: March 28, 2012 Manitoba Corporations Canada Alabama Alaska Arizona Arkansas California Colorado Arizona uses "manager" or "member," but not

More information

SUMMARY: This notice provides information to participants in the Department of

SUMMARY: This notice provides information to participants in the Department of This document is scheduled to be published in the Federal Register on 07/31/2015 and available online at http://federalregister.gov/a/2015-18762, and on FDsys.gov DEPARTMENT OF VETERANS AFFAIRS Loan Guaranty:

More information

Low-Profit Limited Liability Company (L3C) Date: July 29, 2013. [Low-Profit Limited Liability Company (L3C)] [July 29, 2013]

Low-Profit Limited Liability Company (L3C) Date: July 29, 2013. [Low-Profit Limited Liability Company (L3C)] [July 29, 2013] Topic: Question by: : Low-Profit Limited Liability Company (L3C) Kevin Rayburn, Esq., MBA Tennessee Date: July 29, 2013 Manitoba Corporations Canada Alabama Alaska Arizona Arkansas California Colorado

More information

NAIC Annuity Suitability Requirements by State

NAIC Annuity Suitability Requirements by State NAIC Annuity Suitability Requirements by Specific Alabama Alaska 10/16/2011 TBD Arizona Arkansas If you obtained a life insurance license prior to 10/16/11, you must complete the NAIC course by 4/16/12.

More information

State FCRA Rulings. Abide by the Federal Trade Commission s Fair Credit Reporting Act (FCRA), 15 U. S. C. 1661 et seq. and the following state ruling:

State FCRA Rulings. Abide by the Federal Trade Commission s Fair Credit Reporting Act (FCRA), 15 U. S. C. 1661 et seq. and the following state ruling: State FCRA Rulings Alabama Alaska and the following state ruling: AS 12.62.160 (b) (8)Release and Use of Criminal Justice Information Subject to the requirements of this section, and except as otherwise

More information

RENEWAL APPLICATION TECHNOLOGY PROFESSIONAL LIABILITY APPLICATION

RENEWAL APPLICATION TECHNOLOGY PROFESSIONAL LIABILITY APPLICATION Kinsale Insurance Company P. O. Box 17008 Richmond, VA 23226 (804) 289-1300 www.kinsaleins.com RENEWAL APPLICATION TECHNOLOGY PROFESSIONAL LIABILITY APPLICATION APPLICANT S INFORMATION 1. Current Kinsale

More information

Q1 2009 Homeowner Confidence Survey. May 14, 2009

Q1 2009 Homeowner Confidence Survey. May 14, 2009 Q1 2009 Homeowner Confidence Survey Results May 14, 2009 The Zillow Homeowner Confidence Survey is fielded quarterly to determine the confidence level of American homeowners when it comes to the value

More information

Real Progress in Food Code Adoption

Real Progress in Food Code Adoption Real Progress in Food Code Adoption August 27, 2013 The Association of Food and Drug Officials (AFDO), under contract to the Food and Drug Administration, is gathering data on the progress of FDA Food

More information

$7.5 appropriation $6.5 2011 2012 2013 2014 2015 2016. Preschool Development Grants

$7.5 appropriation $6.5 2011 2012 2013 2014 2015 2016. Preschool Development Grants School Readiness: High-Quality Early Learning Head Start $10.5 $9.5 $10.1 +$1.5 +17.7% $8.5 $7.5 +$2.1 +27.0% $6.5 for fiscal year 2010 Included in the budget is $1.078 billion to ensure that every Head

More information

State Tax Information

State Tax Information State Tax Information The information contained in this document is not intended or written as specific legal or tax advice and may not be relied on for purposes of avoiding any state tax penalties. Neither

More information

State Individual Income Taxes: Treatment of Select Itemized Deductions, 2006

State Individual Income Taxes: Treatment of Select Itemized Deductions, 2006 State Individual Income Taxes: Treatment of Select Itemized Deductions, 2006 State Federal Income Tax State General Sales Tax State Personal Property Tax Interest Expenses Medical Expenses Charitable Contributions

More information

A/B MAC Jurisdiction 1 Original Medicare Claims Processor

A/B MAC Jurisdiction 1 Original Medicare Claims Processor A/B MAC Jurisdiction 1 Jurisdiction 1 - American Samoa, California, Guam, Hawaii, Nevada and Northern Mariana Islands Total Number of Fee-For-Service Beneficiaries: 3,141,183 (as of Total Number of Beneficiaries

More information

State Pest Control/Pesticide Application Laws & Regulations. As Compiled by NPMA, as of December 2011

State Pest Control/Pesticide Application Laws & Regulations. As Compiled by NPMA, as of December 2011 State Pest Control/Pesticide Application Laws & As Compiled by NPMA, as of December 2011 Alabama http://alabamaadministrativecode.state.al.us/docs/agr/mcword10agr9.pdf Alabama Pest Control Alaska http://dec.alaska.gov/commish/regulations/pdfs/18%20aac%2090.pdf

More information

Artisan Contractors Application

Artisan Contractors Application Agency Name: Address: Contact Name: Phone: Fax: Email: Artisan Contractors Application All questions must be answered in full. Application must be signed and dated by the applicant. Applicant s Name Agent

More information

Model Regulation Service January 2006 DISCLOSURE FOR SMALL FACE AMOUNT LIFE INSURANCE POLICIES MODEL ACT

Model Regulation Service January 2006 DISCLOSURE FOR SMALL FACE AMOUNT LIFE INSURANCE POLICIES MODEL ACT Table of Contents Section 1. Section 2. Section 3. Section 4. Section 5. Section 6. Section 1. Model Regulation Service January 2006 Purpose Definition Exemptions Disclosure Requirements Insurer Duties

More information

STATE DATA CENTER. District of Columbia MONTHLY BRIEF

STATE DATA CENTER. District of Columbia MONTHLY BRIEF District of Columbia STATE DATA CENTER MONTHLY BRIEF N o v e m b e r 2 0 1 2 District Residents Health Insurance Coverage 2000-2010 By Minwuyelet Azimeraw Joy Phillips, Ph.D. This report is based on data

More information

NAIC Annuity Suitability Requirements by State

NAIC Annuity Suitability Requirements by State NAIC Annuity Suitability Requirements by Specific Alabama Alaska 10/16/2011 TBD Arizona Arkansas If you obtained a life insurance license prior to 10/16/11, you must complete the NAIC course by 4/16/12.

More information

ACE American Insurance Company

ACE American Insurance Company Named Applicant: Date: ACE American Insurance Company ACE Advantage ACE American Insurance Company National Association of REALTORS Professional Liability Name of insurance company to which Application

More information

State by State Summary of Nurses Allowed to Perform Conservative Sharp Debridement

State by State Summary of Nurses Allowed to Perform Conservative Sharp Debridement State by State Summary of Nurses Allowed to Perform Conservative Sharp Debridement THE FOLLOWING ARE ONLY GENERAL SUMMARIES OF THE PRACTICE ACTS EACH STATE HAS REGARDING CONSERVATIVE SHARP DEBRIDEMENT

More information

Supreme Court Strikes Down DOMA, Clears Way for Same-Sex Marriage in California

Supreme Court Strikes Down DOMA, Clears Way for Same-Sex Marriage in California Brought to you by Alamo Insurance Group Supreme Court Strikes Down DOMA, Clears Way for Same-Sex On June 26, 2013, the U.S. Supreme Court announced decisions in two significant cases regarding laws affecting

More information

Expanding Your Business Through Franchising What Steps You Need to Take to Successfully Franchise Your Business. By Robert J.

Expanding Your Business Through Franchising What Steps You Need to Take to Successfully Franchise Your Business. By Robert J. Expanding Your Business Through Franchising What Steps You Need to Take to Successfully Franchise Your Business By Robert J. Steinberger What is a Franchise? California Corporation Code Section 31005.

More information

Use of "Mail Box" service. Date: April 6, 2015. [Use of Mail Box Service] [April 6, 2015]

Use of Mail Box service. Date: April 6, 2015. [Use of Mail Box Service] [April 6, 2015] Topic: Question by: : Use of "Mail Box" service Kathy M. Sachs Kansas Date: April 6, 2015 Manitoba Corporations Canada Alabama Alaska Arizona Arkansas California Colorado Connecticut Delaware District

More information

Reporting of Board Discipline. Mark Johnston, RPh Executive Director Idaho State Board of Pharmacy

Reporting of Board Discipline. Mark Johnston, RPh Executive Director Idaho State Board of Pharmacy Reporting of Board Discipline Mark Johnston, RPh Executive Director Idaho State Board of Pharmacy HIPDB The Healthcare Integrity and Protection Data Bank Part of the Health Care Fraud and Abuse Control

More information

Hole-In-One Application

Hole-In-One Application > Hole-In-One Application All questions must be answered in full. Application must be signed and dated by the applicant.

More information

TABLE OF CONTENTS 1.00 ORGANIZATION AND AUTHORITY 1.01 TAX DIVISION AUTHORITY... 1-1 1.02 CRIMINAL ENFORCEMENT SECTIONS ORGANIZATION CHART...

TABLE OF CONTENTS 1.00 ORGANIZATION AND AUTHORITY 1.01 TAX DIVISION AUTHORITY... 1-1 1.02 CRIMINAL ENFORCEMENT SECTIONS ORGANIZATION CHART... TABLE OF CONTENTS 1.00 ORGANIZATION AND AUTHORITY 1.01 TAX DIVISION AUTHORITY... 1-1 1.02 CRIMINAL ENFORCEMENT SECTIONS ORGANIZATION CHART... 1-3 1.03 CRIMINAL ENFORCEMENT SECTIONS -- DELEGATION OF AUTHORITY...

More information

Alarm or Security System Design, Installation, Service or Repair Application

Alarm or Security System Design, Installation, Service or Repair Application Alarm or Security System Design, Installation, Service or Repair Application All questions must be answered in full. Application must be signed and dated by the applicant. Applicant s Name Agent Applicant

More information

Overview of the Deficit Reduction Act and State False Claims

Overview of the Deficit Reduction Act and State False Claims Overview of the Deficit Reduction Act and State False Claims Massachusetts Extended Care Federation Lombardo's, Randolph, Massachusetts June 14, 2007 C. Elizabeth O Keeffe Foley & Lardner LLP Attorney

More information

Internet Prescribing Summary

Internet Prescribing Summary Internet Prescribing Summary, Minnesota,,, South Dakota and Wisconsin (July 2011) Advancements in medicine and technology have transformed the way health care is delivered to patients. However, laws governing

More information

(In effect as of January 1, 2004*) TABLE 5a. MEDICAL BENEFITS PROVIDED BY WORKERS' COMPENSATION STATUTES FECA LHWCA

(In effect as of January 1, 2004*) TABLE 5a. MEDICAL BENEFITS PROVIDED BY WORKERS' COMPENSATION STATUTES FECA LHWCA (In effect as of January 1, 2004*) TABLE 5a. MEDICAL BENEFITS PROVIDED BY WORKERS' COMPENSATION STATUTES Full Medical Benefits** Alabama Indiana Nebraska South Carolina Alaska Iowa Nevada South Dakota

More information

CLAIMS ADJUSTERS ERRORS & OMISSIONS APPLICATION

CLAIMS ADJUSTERS ERRORS & OMISSIONS APPLICATION APPLICANT S INFORMATION CLAIMS ADJUSTERS ERRORS & OMISSIONS APPLICATION 1. Legal name of the business who is the primary applicant and will be the first named insured listed on the policy: 2. Please list

More information

Product Liability Application All questions must be answered in full. Application must be signed and dated by the applicant.

Product Liability Application All questions must be answered in full. Application must be signed and dated by the applicant. Agency Name: Address: Contact Name: Phone: Fax: Email: Product Liability Application All questions must be answered in full. Application must be signed and dated by the applicant. Applicant s Name Agent

More information

55144-1-5 Page: 1 of 5. Pharmacy Fraud, Waste and Abuse Policy. 1.0 Compliance Assurance. 2.0 Procedure

55144-1-5 Page: 1 of 5. Pharmacy Fraud, Waste and Abuse Policy. 1.0 Compliance Assurance. 2.0 Procedure Pharmacy Fraud, Waste and Abuse Policy 1.0 Compliance Assurance This Fraud Waste and Abuse Policy ( Policy ) reiterates the commitment of this pharmacy to comply with the standards of conduct established

More information

Alabama: Examples of fraud include the following:

Alabama: Examples of fraud include the following: Alabama: Alabama law does not provide for civil false claim actions, as does the federal False Claims Act, but prosecutors may bring criminal actions against any person who knowingly makes or causes to

More information

MERS Recommended Foreclosure Procedures

MERS Recommended Foreclosure Procedures State-by-State MERS Recommended Foreclosure Procedures Updated 2002 Corporate Offices 1818 Library Street, Suite 300 Reston, VA 20190 tel (800) 646-6377 fax (703) 748-0183 www.mersinc.org TABLE OF CONTENTS

More information

A-79. Appendix A Overview and Detailed Tables

A-79. Appendix A Overview and Detailed Tables Table A-8a. Overview: Laws Expressly Granting Minors the Right to Consent Disclosure of Related Information to Parents* Sexually Transmitted Disease and HIV/AIDS** Treatment Given or Needed Alabama 14

More information

We do require the name and mailing address of each person forming the LLC.

We do require the name and mailing address of each person forming the LLC. Topic: LLC Managers/Members Question by: Jeff Harvey : Idaho Date: March 7, 2012 Manitoba Corporations Canada Alabama Alaska Arizona Arkansas California Colorado Arizona requires that member-managed LLCs

More information

Commission Membership

Commission Membership Multistate Tax Commission Update Joe Huddleston Executive Director 2008 Federation of Tax Administrators Annual Meeting Philadelphia, Pennsylvania Commission hip As of July 1, 2007 Compact Sovereignty

More information

LPSC Renewable Energy Pilot y RFPs issued by Utility Companies by Order of Commission, November 2010

LPSC Renewable Energy Pilot y RFPs issued by Utility Companies by Order of Commission, November 2010 Renewable Energy LPSC Renewable Energy Pilot y RFPs issued by Utility Companies by Order of Commission, November 2010 y Searching for various forms of renewable energy and their actual cost in Louisiana

More information

Understanding the Affordable Care Act

Understanding the Affordable Care Act Understanding the Affordable Care Act The Affordable Care Act (officially called the Patient Protection and Affordable Care Act) is the law that mandates that everyone in the United States maintain health

More information

STATE MOTORCYCLE LEMON LAW SUMMARIES

STATE MOTORCYCLE LEMON LAW SUMMARIES STATE MOTORCYCLE LEMON LAW SUMMARIES The Federal Lemon Law covers motorcycles and each state also has its own unique Lemon Law. In the chart below, Covered means whether or not a motorcycle is normally

More information

Medicaid Topics Impact of Medicare Dual Eligibles Stephen Wilhide, Consultant

Medicaid Topics Impact of Medicare Dual Eligibles Stephen Wilhide, Consultant Medicaid Topics Impact of Medicare Dual Eligibles Stephen Wilhide, Consultant Issue Summary The term dual eligible refers to the almost 7.5 milion low-income older individuals or younger persons with disabilities

More information

State Tax of Social Security Income. State Tax of Pension Income. State

State Tax of Social Security Income. State Tax of Pension Income. State State Taxation of Retirement Income The following chart shows generally which states tax retirement income, including and pension States shaded indicate they do not tax these forms of retirement State

More information

False Claims Act Investigations + Defense Practice

False Claims Act Investigations + Defense Practice False Claims Act Investigations + Defense Practice 2015 Morrison & Foerster LLP All Rights Reserved mofo.com WHAT IS IT? First passed by President Lincoln during the Civil War to penalize military suppliers

More information

DEPARTMENT OF VETERANS AFFAIRS Billing Code 8320-01. Loan Guaranty: Maximum Allowable Foreclosure Timeframes.

DEPARTMENT OF VETERANS AFFAIRS Billing Code 8320-01. Loan Guaranty: Maximum Allowable Foreclosure Timeframes. This document is scheduled to be published in the Federal Register on 12/04/2015 and available online at http://federalregister.gov/a/2015-30592, and on FDsys.gov DEPARTMENT OF VETERANS AFFAIRS Billing

More information

State Drivers License Identification & Resource Directory Prepared by:

State Drivers License Identification & Resource Directory Prepared by: State Drivers License Identification & Resource Directory Prepared by: Northwind International Corp. Grand Rapids, MI (866) 977 7900 State Driver s License Formats State License Format Alabama Alaska Arizona

More information

LLC Member/Manager Disclosure Question by: Cathy Beaudoin. Jurisdiction. Date: 01 March 2011. LLC Member/Manager Disclosure 2011 March 01

LLC Member/Manager Disclosure Question by: Cathy Beaudoin. Jurisdiction. Date: 01 March 2011. LLC Member/Manager Disclosure 2011 March 01 Topic: LLC Member/Manager Disclosure Question by: Cathy Beaudoin : Maine Date: 01 March 2011 Manitoba Corporations Canada Alabama Alaska Arizona Arkansas California Our statement of information (aka annual

More information

Tax Research: Understanding Sources of Tax Law (Why my IRC beats your Rev Proc!)

Tax Research: Understanding Sources of Tax Law (Why my IRC beats your Rev Proc!) Tax Research: Understanding Sources of Tax Law (Why my IRC beats your Rev Proc!) Understanding the Federal Courts There are three levels of Federal courts that hear tax cases. At the bottom of the hierarchy,

More information

Supplier Business Continuity Survey - Update Page 1

Supplier Business Continuity Survey - Update Page 1 Supplier Business Continuity Survey - Update Page 1 Supplier Business Continuity Survey A response is required for every question General Information Supplier Name: JCI Supplier Number: Supplier Facility

More information

SUPPLEMENTAL APPLICATION COMMERCIAL GENERAL LIABILITY COMPLETE IN ADDITION TO ACORD APPLICATIONS. ATTACH ADDITIONAL SHEETS AS NECESSARY.

SUPPLEMENTAL APPLICATION COMMERCIAL GENERAL LIABILITY COMPLETE IN ADDITION TO ACORD APPLICATIONS. ATTACH ADDITIONAL SHEETS AS NECESSARY. Kinsale Insurance Company P. O. Box 17008 Richmond, VA 23226 (804) 289-1300 www.kinsaleins.com MANUFACTURERS SUPPLEMENTAL APPLICATION COMMERCIAL GENERAL LIABILITY COMPLETE IN ADDITION TO ACORD APPLICATIONS.

More information

Census Data on Uninsured Women and Children September 2009

Census Data on Uninsured Women and Children September 2009 March of Dimes Foundation Office of Government Affairs 1146 19 th Street, NW, 6 th Floor Washington, DC 20036 Telephone (202) 659-1800 Fax (202) 296-2964 marchofdimes.com nacersano.org Census Data on Uninsured

More information

Recruitment and Retention Resources By State List

Recruitment and Retention Resources By State List Recruitment and Retention Resources By State List Alabama $5,000 rural physician tax credit o http://codes.lp.findlaw.com/alcode/40/18/4a/40-18-132 o http://adph.org/ruralhealth/index.asp?id=882 Area Health

More information

State Corporate Income Tax Rates As of July 1, 2009

State Corporate Income Tax Rates As of July 1, 2009 State Tax Rates and Special Rates or Notes Brackets Alabama 6.5% Federal deductibility Alaska 1.0% > $0 2.0 > 10K 3.0 > 20K 4.0 > 30K 5.0 > 40K 6.0 > 50K 7.0 > 60K 8.0 > 70K 9.0 > 80K 9.4 > 90K Arizona

More information

Outpatient dialysis services

Outpatient dialysis services O n l i n e A p p e n d i x e s 6 Outpatient dialysis services 6-A O n l i n e A p p e n d i x Medicare spending by dialysis beneficiaries is substantial FIGURE 1-3 Figure 6 A1 Medicare population Dialysis

More information

What to Know About State CPA Reciprocity Rules. John Gillett, PhD, CPA Chair, Department of Accounting Bradley University, Peoria, IL

What to Know About State CPA Reciprocity Rules. John Gillett, PhD, CPA Chair, Department of Accounting Bradley University, Peoria, IL What to Know About State CPA Reciprocity Rules Paul Swanson, MBA, CPA Instructor of Accounting John Gillett, PhD, CPA Chair, Department of Accounting Kevin Berry, PhD, Assistant Professor of Accounting

More information

GUARANTEE TRUST LIFE INSURANCE COMPANY Credit Claim Service Center P.O. Box 1145 Glenview, IL 60025 Phone: 800-592-0629 Fax: 847-460-2962

GUARANTEE TRUST LIFE INSURANCE COMPANY Credit Claim Service Center P.O. Box 1145 Glenview, IL 60025 Phone: 800-592-0629 Fax: 847-460-2962 Initial Credit Disability Claim Form GUARANTEE TRUST LIFE INSURANCE COMPANY Credit Claim Service Center P.O. Box 1145 Glenview, IL 60025 Phone: 800-592-0629 Fax: 847-460-2962 Office Hours: Monday thru

More information

US Department of Health and Human Services Exclusion Program. Thomas Sowinski Special Agent in Charge/ Reviewing Official

US Department of Health and Human Services Exclusion Program. Thomas Sowinski Special Agent in Charge/ Reviewing Official US Department of Health and Human Services Exclusion Program Thomas Sowinski Special Agent in Charge/ Reviewing Official Overview Authority to exclude individuals and entities from Federal Health Care

More information

Prepared by : Michael R. Fowlkes CBP / Fraudulent Document Officer San Ysidro Port of Entry 720 E. San Ysidro Blvd. San Ysidro, CA 92173 (619)

Prepared by : Michael R. Fowlkes CBP / Fraudulent Document Officer San Ysidro Port of Entry 720 E. San Ysidro Blvd. San Ysidro, CA 92173 (619) Prepared by : Michael R. Fowlkes CBP / Fraudulent Document Officer San Ysidro Port of Entry 720 E. San Ysidro Blvd. San Ysidro, CA 92173 (619) 662-7342 Social Security Facts: The Social Security act was

More information

Model Regulation Service July 2005 LIFE INSURANCE MULTIPLE POLICY MODEL REGULATION

Model Regulation Service July 2005 LIFE INSURANCE MULTIPLE POLICY MODEL REGULATION Table of Contents Section 1. Section 2. Section 3. Section 4. Section 5. Section 6. Section 1. Model Regulation Service July 2005 Purpose Authority Exemptions Duties of Insurers Severability Effective

More information

Exhibit 57A. Approved Attorney Fees and Title Expenses

Exhibit 57A. Approved Attorney Fees and Title Expenses Exhibit 57A Approved Attorney Fees and Title Expenses Written pre-approval from Freddie Mac is required before incurring any expense in excess of any of the below amounts. See Sections 71.19 and 71.24

More information

Virginia Medicaid Fraud Control Unit

Virginia Medicaid Fraud Control Unit VIRGINIA ATTORNEY GENERAL S OFFICE Virginia Medicaid Fraud Control Unit SPECIAL POINTS OF INTEREST: Services VOLUME 1, ISSUE 3 SEPTEMBER 2010 The Medicaid Fraud Control Unit s Civil Unit Case Spotlight

More information

False Claims Act Investigations + Defense Practice

False Claims Act Investigations + Defense Practice False Claims Act Investigations + Defense Practice 2014 Morrison & Foerster LLP All Rights Reserved mofo.com WHAT IS IT First passed by President Lincoln during the Civil War to penalize military suppliers

More information

States Ranked by Alcohol Tax Rates: Beer (as of March 2009) Ranking State Beer Tax (per gallon)

States Ranked by Alcohol Tax Rates: Beer (as of March 2009) Ranking State Beer Tax (per gallon) States Ranked by Alcohol Tax Rates: Beer (as of March 2009) Ranking State Beer Tax (per gallon) Sales Tax Applied 1 Wyoming $0.02 4% 2 4 8 10 Missouri $0.06 4.225% Wisconsin $0.06 5% Colorado $0.08 2.9%

More information

Whistling While You Work: Dangers of a Qui Tam Lawsuit and How to Avoid Them

Whistling While You Work: Dangers of a Qui Tam Lawsuit and How to Avoid Them Whistling While You Work: Dangers of a Qui Tam Lawsuit and How to Avoid Them Presented By: John T. Brennan, Jr. David W. O Brien Michael W. Paddock The False Claims Act Primary government weapon in combating

More information

14-Sep-15 State and Local Tax Deduction by State, Tax Year 2013

14-Sep-15 State and Local Tax Deduction by State, Tax Year 2013 14-Sep-15 State and Local Tax Deduction by State, Tax Year 2013 (millions) deduction in state dollars) claimed (dollars) taxes paid [1] state AGI United States 44.2 100.0 30.2 507.7 100.0 11,483 100.0

More information