Is Each Flawed Invoice A False Claims Act Violation?

The whistleblower provision of The False Claims Act can result in a civil penalty of  between $5,500 and $11,000 for each statutory violation, in addition to a fine based on actual damages. The tab can mount quickly if every flawed invoice counts as a separate violation – should it? The traditionally business-friendly Fourth Circuit Court of Appeals in Richmond gave a surprising answer to that question, write Ogletree Deakins attorneys Chris V. Anderson and Margaret H. Campbell, and they offer some tips for companies that want to avoid this potentially expensive trap.