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False Claims Act Hot Topics (2026 Edition)

The False Claims Act is moving: the Eleventh Circuit’s Zafirov opinion, an updated Justice Manual on § 3730(c)(2)(a) dismissals, and settlement trends in Medicare Part C. Learn the next steps post-Zafirov, the Government’s dismissal posture, and the compliance moves that mitigate risk.

2026-11-03 12:00:00

1 hours

Program Details

2026-11-03 12:00:00

2026-11-03 12:00:00

1h CLE Credits

2026-11-03 12:00:00

1 hours

Program Details

2026-11-03 12:00:00

Program Details

2026-11-03 12:00:00

Over 1,000+ webinars

2026-11-03 12:00:00

1 hours

Course Overview

Three developments are redrawing the FCA practitioner’s radar

2026-11-03 12:00:00

The False Claims Act — the “Lincoln Law” — impacts a variety of sectors, and three recent items belong on every FCA practitioner’s radar. First, the Eleventh Circuit’s Zafirov opinion, which puts the FCA under the Appointments Clause. Second, the Justice Manual update regarding § 3730(c)(2)(a). Third, developments in the sector that contributes the most recoveries: healthcare.

Each carries consequences. Zafirov’s holding invites next steps that practitioners and their clients must anticipate. The updated Justice Manual reframes the Government’s use of its authority to dismiss cases. And Medicare Part C updates are shaping where FCA settlements trend.

Attendees leave able to appreciate the post-Zafirov landscape, the ramifications of the updated § 3730(c)(2)(a) interpretation, and the trends in FCA settlements involving Medicare Part C — along with how compliance programs can mitigate risk.

Format

CLE Credit

1h CLE Credits

Level

Intermediate

Length

1

Key topics that will be covered

01
Zafirov and the Appointments Clause
Next steps following the Eleventh Circuit’s Zafirov holding on the FCA under the Appointments Clause.
02
Three Items for the Radar
The three recent developments FCA practitioners and their clients should be tracking under the “Lincoln Law.”
03
Government Dismissal Authority
Ramifications of the updated Justice Manual’s interpretation of § 3730(c)(2)(a) and the Government’s use of its authority to dismiss cases.
04
Healthcare’s Outsized Share
Why healthcare — the sector that contributes the most recoveries under the FCA — sits at the center of enforcement.
05
Medicare Part C Settlement Trends
Trends in FCA settlements involving Medicare Part C.
06
Compliance That Mitigates Risk
How compliance programs can mitigate FCA risk.

Program schedule

clock 12:00 pm - 1:00 pm EST

False Claims Act Hot Topics

The False Claims Act (FCA), also known as the “Lincoln Law”, impacts a variety of sectors. There are three recent notable items that should be on FCA practitioners and their clients’ radars. First, the Eleventh Circuit’s Zafirov Opinion. Second, the update to the Justice Manual regarding 3730(c)(2)(a) and the Government’s use of its authority to dismiss cases. Lastly, as healthcare is the sector that contributes most recoveries under the FCA, Medicare Part C updates will be discussed, along with how compliance programs can mitigate risk.

Rachel V. RoseRachel V. Rose
Rachel V. Rose

Rachel V. Rose

Rachel V. Rose – Attorney at Law, PLLC

Rachel V. Rose

Rachel V. Rose

Rachel V. Rose – Attorney at Law, PLLC

Rachel V. Rose, JD, MBA successfully advises and represents clients on healthcare, cybersecurity, securities, and qui tam compliance, transactional, litigation, and government enforcement matters. Ms. Rose is also an Affiliated Member with the Baylor College of Medicine’s Center for Medical Ethics and Health Policy, where she teaches bioethics.

Education & Credentials

Ms. Rose holds an MBA with minors in healthcare and entrepreneurship from Vanderbilt University, and a law degree from Stetson University College of Law, where she graduated with various honors, including the National Scribes Award. Ms. Rose also attained a Certificate in Negotiation and Leadership from Harvard University. Ms. Rose is licensed in Texas and is a Fellow of the Federal Bar Association and the American Bar Association.

Recognition & Leadership

She has been named consecutively to the Texas Bar College, the National Women Trial Lawyers Association’s Top 25, Houstonia Magazine’s Top Lawyers (healthcare), the National Trial Lawyers Association’s Top 100 and The Nation’s Top One Percent and SuperLawyers (healthcare). Ms. Rose was awarded 1st Healthcare Compliance’s 2019 and 2022 Top Presenter Award, as well as receiving NBI’s Outstanding Faculty Award for the past several years.

Professional Involvement

Currently, she serves as a Director on the Foundation of the Federal Bar Association’s National Board, is a Past Chair of the Federal Bar Association’s Government Relations Committee, an Advisory Board member of the Federal Bar Association’s Qui Tam Section, the co-editor of the American Health Lawyers Association’s Enterprise Risk Management Handbook for Healthcare Entities (2nd Edition), as well as a co-author of the ABA’s books The ABCs of ACOs, What Are International HIPAA Considerations and International HIPAA, Privacy, and Security Law Considerations, as well as book chapters for a variety of legal and medical books, including Health Law Handbook (2026 Edition).

Experience

In addition to being extensively published, a sought-after presenter and often quoted in a variety of publications, she has served as a testifying and as a consultative expert. She has conducted HIPAA risk analyses and assisted clients post-breach since 2012.
Rachel V. Rose

Rachel V. Rose

Rachel V. Rose – Attorney at Law, PLLC

Rachel V. Rose, JD, MBA successfully advises and represents clients on healthcare, cybersecurity, securities, and qui tam compliance, transactional, litigation, and government enforcement matters. Ms. Rose is also an Affiliated Member with the Baylor College of Medicine’s Center for Medical Ethics and Health Policy, where she teaches bioethics.

Education & Credentials

Ms. Rose holds an MBA with minors in healthcare and entrepreneurship from Vanderbilt University, and a law degree from Stetson University College of Law, where she graduated with various honors, including the National Scribes Award. Ms. Rose also attained a Certificate in Negotiation and Leadership from Harvard University. Ms. Rose is licensed in Texas and is a Fellow of the Federal Bar Association and the American Bar Association.

Recognition & Leadership

She has been named consecutively to the Texas Bar College, the National Women Trial Lawyers Association’s Top 25, Houstonia Magazine’s Top Lawyers (healthcare), the National Trial Lawyers Association’s Top 100 and The Nation’s Top One Percent and SuperLawyers (healthcare). Ms. Rose was awarded 1st Healthcare Compliance’s 2019 and 2022 Top Presenter Award, as well as receiving NBI’s Outstanding Faculty Award for the past several years.

Professional Involvement

Currently, she serves as a Director on the Foundation of the Federal Bar Association’s National Board, is a Past Chair of the Federal Bar Association’s Government Relations Committee, an Advisory Board member of the Federal Bar Association’s Qui Tam Section, the co-editor of the American Health Lawyers Association’s Enterprise Risk Management Handbook for Healthcare Entities (2nd Edition), as well as a co-author of the ABA’s books The ABCs of ACOs, What Are International HIPAA Considerations and International HIPAA, Privacy, and Security Law Considerations, as well as book chapters for a variety of legal and medical books, including Health Law Handbook (2026 Edition).

Experience

In addition to being extensively published, a sought-after presenter and often quoted in a variety of publications, she has served as a testifying and as a consultative expert. She has conducted HIPAA risk analyses and assisted clients post-breach since 2012.

Credits by state

AK1.0
AL1.0
AR1.0
AZ1.0
CA1.0
CO1.0
CT1.0
DC1.0
DE1.0
FL1.0
GA1.0
HI1.0
IA1.0
ID1.0
IL1.0
IN1.0
KS1.0
KY1.0
LA1.0
MA1.0
MD1.0
ME1.0
MI1.0
MN1.0
MO1.2
MS1.0
MT1.0
NC1.0
ND1.0
NE1.0
NH60.0
NJ1.0
NM1.0
NV1.0
NY1.0
OH1.0
OK1.0
OR1.0
PA1.0
RI1.0
SC1.0
SD1.0
TN1.0
TX1.0
UT1.0
VA1.0
VT1.0
WA1.0
WI1.0
WV1.2
WY1.0

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

10,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

MCLE Credits

Alabama
Pending
Alaska
Approved
Arizona
Approved
Arkansas
Approved
California
Approved
Colorado
Pending
Connecticut
Approved
Delaware
Pending
District of Columbia
No Required
Florida
Approved
Georgia
Pending
Hawaii
Approved
Idaho
Pending
Illinois
Pending
Indiana
Pending
Iowa
Pending
Kansas
Pending
Kentucky
Pending
Louisiana
Pending
Maine
Pending
Maryland
No Required
Massachusetts
No Required
Michigan
No Required
Minnesota
Pending
Mississippi
Pending
Missouri
Approved
Montana
Pending
Nebraska
Pending
Nevada
Pending
New Hampshire
Approved
New Jersey
Approved
New Mexico
Approved
New York
Approved
North Carolina
Pending
North Dakota
Approved
Ohio
Pending
Oklahoma
Pending
Oregon
Pending
Pennsylvania
Approved
Rhode Island
Pending
South Carolina
Pending
South Dakota
No Required
Tennessee
Pending
Texas
Approved
Utah
Pending
Vermont
Approved
Virginia
Not Eligible
Washington
Approved
West Virginia
Pending
Wisconsin
Pending
Wyoming
Pending

Alabama

Requirements

The Alabama State Bar MCLE Commission requires attorneys to complete 12 credits, including 1 ethics, by December 31 of each year. All credits must be reported by February 15 of the following year. A maximum of 12 credits, including 1 ethics credit, may be carried over for 1 year only.  

Formats

  • Attorneys can earn unlimited “live” credit through live seminars, live webcasts, and co-sponsored locations with MyLAWCLE-Alabama approved programs
  • Attorneys are limited to 6 credits per compliance period of “online” programs through MyLAwCLE On-Demand programs