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Special Master Confirms Materiality Requirement for Reverse False Claims Act Liability

Morenike Oyebade and Valerie Cohen

Special Master Confirms Materiality Requirement for Reverse False Claims Act Liability
Juan Moyano via Getty Images

In a March 3, 2025 report and recommendation (R&R), a court-appointed special master in  U.S. ex rel. Poehling v. UnitedHealth Group, Inc., No. cv 16-08697-FMO-PVCx, 2025 WL 682285 (C.D. Cal. Mar. 3, 2025), found that materiality is an essential element for liability under the reverse false claims provision of the False Claims Act (FCA) and, therefore, the Department of Justice (DOJ) does not have evidence to support their FCA claims. In its R&R, the special master recommended the denial of the motion for partial summary judgment submitted by the DOJ on the issue that materiality is not required for liability under the second prong of the reverse false claim provision—commonly referred to as the “avoids” prong—which imposes liability on a person who “knowingly and improperly avoids or decreases an obligation to pay…the Government.” 31 U.S.C. § 3729(a)(1)(G). 

The case itself centers on allegations that Medicare Advantage plan defendants improperly retained Medicare Advantage payments that they should have repaid to the government. Those payments stemmed from diagnosis codes that the DOJ alleged the defendants should have identified as not supported by medical records during defendants’ chart review process. As explained in the R&R, Medicare Advantage plans “may obtain and review patients’ medical records to identify additional codes doctors may have failed to include in submitting claim forms”—a process commonly referred to as a “chart review.” Poehling, 2025 WL 682285, at *6. Defendants’ chart reviews were generally conducted “in a ‘blind’ manner, meaning a coder reviewing a medical record did not know what diagnosis codes the doctor had submitted.” Id. Defendants argued, among other things, that by coding blindly, coders did not know whether some of the diagnosis codes previously submitted by treating providers were unsupported by medical records—precluding the requisite reverse FCA knowledge element. Defendants also argued that they disclosed to their regulator, the Centers for Medicare & Medicaid Services (CMS), the nature of their chart review program, including the fact that it did not search for potentially unsupported diagnosis codes. This disclosure, the special master reasoned, meant that “CMS undeniably knew for years about United’s practices and was aware when it made the challenged payments that United’s coders never sought to independently confirm the validity of the diagnostic codes identified by the doctors.” Id. at *20. Defendants had argued that CMS’s continued payments demonstrated that the chart review program operation was not material to the agency’s payment decision, defeating another essential element for reverse FCA liability. 

Against this backdrop, the DOJ sought partial summary judgment, arguing that materiality should not apply to the “avoids” prong of the reverse false claims provision based on the provision’s plain text and on district court precedent in the Ninth Circuit and other circuits. The special master rejected the DOJ’s position, explaining that while the at-issue provision does not explicitly reference it, materiality is an inherent fraud requirement, citing the Supreme Court’s Universal Health Servs., Inc. v.United States ex rel. Escobar decision and Ninth Circuit precedent. Id. at *19. The special master found DOJ’s cited cases non-binding and unpersuasive, determining that they did “not thoroughly analyze” materiality under the “avoids” prong of the reverse FCA. Id. As the special master elaborated, “a materiality element must apply to that provision, regardless of which of its two prongs is the basis for the government’s claim in a given case, because of the inconceivability of fraud absent a materiality element.” Id.

The special master also highlighted the “adverse consequences” of disregarding materiality, warning that doing so may allow the government to pursue reverse FCA liability (rather than affirmative FCA claims) to avoid establishing materiality. Id. at *20. Another concern was that the government would pursue reverse FCA claims even where it was fully aware of the alleged misconduct and continued making payments, as in the instant case. This “type of behavior by the government,” the special master continued, “has been recognized as a factor undermining a ‘false claim’ or materiality contention,” even if “not dispositive.” Id. The R&R therefore reinforces the principle that the government’s knowledge and continued payments can indicate that an alleged false claim was not material.

However, the dispute is not over. The DOJ’s response disputing the R&R is due April 2, 2025. Defendants’ response is due May 2, 2025, and DOJ’s reply is due May 19, 2025—setting the stage for further litigation on the materiality issue, among others. This is a case to watch for litigants in other Medicare Advantage chart review cases and for the FCA bar at large.