Brian Stimson (Alston & Bird) has a working paper from WLF (press release) on how prosecutors are using the False Claims Act "as a tool for enforcing compliance with federal health care quality standards". Under something known as the "implied false certification doctrine," accepted by some courts, "implied misrepresentations of statutory, regulatory, and contractual compliance are as actionable as express falsehoods" -- which can have the effect of turning the FCA into a general federal health law barbed with treble-damage provisions as well as per-incident fines, even in cases where patients were not harmed or duplicative or unneeded services billed for.