Annie E Railton

Annie E Railton

December 13, 2019 | New York Law Journal

New Attack on Physician Compensation Models Under the Stark Law

In their Federal Civil Enforcement column, William Harrington, Annie Railton and Roger Cohen analyze a recent decision by the U.S. Court of Appeals for the Third Circuit, which has thrown in doubt the common practice of hospitals paying doctors based on the amount of work those doctors do.

By William J. Harrington, Annie E. Railton and Roger A. Cohen

8 minute read

June 27, 2019 | New York Law Journal

Does Violating Medicare Regulatory Guidance Still Create False Claims Act Liability?

In their Federal Civil Enforcement column, William J. Harrington and Annie E. Railton discuss 'Azar v. Allina Health Services', which suggests a new line of attack on the aggressive use of regulatory guidance in FCA cases: challenges not to the appropriateness of looking to guidance documents in a particular action, but to the very validity of the guidance itself.

By William J. Harrington and Annie E. Railton

8 minute read

June 28, 2018 | New York Law Journal

Two Recent Cases Illustrate Need to Rely on Causal Concepts in FCA Cases

In their Federal Civil Enforcement column, Richard Strassberg, William Harrington and Annie E. Railton write: In 2010, Congress amended the anti-kickback statute (AKS) to confirm that claims “resulting from” illegal kickbacks are false and thus actionable under the federal False Claims Act (FCA).

By Richard Strassberg, William Harrington and Annie E. Railton

1 minute read