United States Ex Rel. Gonzalez v. Fresenius Medical Care North America
Relator Rebecca Gonzalez, a former Fresenius employee, brought a qui tam action under the False Claims Act (FCA) against Fresenius Medical Care North America, BioMedical Applications of Texas, Inc., Fresenius Medical Care Holdings, Inc., Larry Ramirez, and Alfonso Chavez. Gonzalez alleged that Fresenius and Chavez submitted false or fraudulent claims to Medicare by using unlicensed medical assistants and engaging in an illegal referral scheme violating anti-kickback and Stark laws. She also claimed retaliation and intentional infliction of emotional distress. The Court granted in part and denied in part the defendants' motions for judgment as a matter of law, dismissing most of Gonzalez's claims against Fresenius and some against Chavez due to insufficient evidence regarding express or implied certifications of compliance, lack of criminal intent, or the unviability of certain legal theories in the Fifth Circuit. However, claims against Chavez regarding factual falsity under FCA (a)(1) and related (a)(2) and (a)(3) liability were allowed to proceed to a jury.