William J Harrington

William J Harrington

April 26, 2023 | New York Law Journal

The False Claims Act and Kickbacks: Factual Causality Required

At the heart of the development is a question about the meaning of a 2010 legislative change, when Congress said that the FCA applies to claims for items or services "resulting from" illegal remuneration paid for health care referrals in violation of the Anti-Kickback Statute (AKS).

By William J. Harrington, Annie Railton and Roland Chang

9 minute read

June 08, 2022 | New York Law Journal

Chopra's Deputies: State Attorneys General and Consumer Protection

The new Director is seeking to flex and strengthen all of CFPB's dormant muscles.

By William J. Harrington and W. Kyle Tayman

9 minute read

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