Federal Bar Association Qui Tam Section: The FCA and Gatekeeper Fraud

Join Verrill Partner Jay McCormack for the Federal Bar Association Qui Tam Section: The FCA and Gatekeeper Fraud webinar on April 8, 2026. 

The federal government is increasingly relying on private “gate-keepers” to certify, credential, or otherwise approve participants in Government programs (both individuals and entities) to ensure adherence to regulatory standards. For example, JCAHO certifies hospitals, NCQA certifies MCOs, HQAA certifies DME suppliers, and other entities approve EHR software used by various health systems. When do relators have a viable FCA claim if there is fraud in the certification and/or credentialing process, either on the gate-keeper by companies seeking to obtain necessary approval to obtain access to government programs and funds, or by the gate-keeper performing the quasi-governmental function? What are the unique challenges of these types of FCA cases? What defenses might be raised? Looking ahead, how might these cases impact future FCA cases relating to the misuse of AI devices? Or to the activities of quasi-governmental entities like DOGE?

Register for the event.