Supreme Court Refuses to Restrict the Definition of “Claim” Under the False Claims Act: Insights From Wisconsin Bell, Inc. v. U.S. ex Rel. Heath
How is a “claim” defined under the False Claims Act (FCA)?
The Supreme Court’s recent decision in Wisconsin Bell, Inc. v. U.S. ex rel. Heath has shed new light on a critical aspect of the False Claims Act (FCA)—what exactly constitutes a “claim.”
The FCA’s Purpose
At its core, the FCA is designed to deter and penalize fraudulent attempts to obtain government funds. Traditionally, a “claim” under the Act has been understood to include any invoice, billing statement, or written demand for payment submitted to the government. However, disputes have long arisen over whether certain communications or representations—those that might not explicitly state a demand for payment—fall within this definition.
Wisconsin Bell, Inc. v. U.S. ex Rel. Heath
Understanding the Case
In this case, the Supreme Court clarified that the essence of a “claim” is not confined solely to formal, conventional billing documents. Instead, the Court held that a statement qualifies as a “claim” if it is intended to induce the government to expend funds. In other words, even if the document or communication does not expressly call itself an invoice or contain an explicit request for payment, it can still trigger FCA liability if its practical effect is to prompt a financial transaction with the government.
By focusing on the function and purpose of the communication—namely, its role in eliciting government payment—the Court ensured that potentially fraudulent representations cannot escape scrutiny merely through technical or formalistic defenses. For legal practitioners, this decision offers a clear benchmark: if a submission or representation is designed to obtain government reimbursement, it meets the definition of a “claim” under the FCA, regardless of its form.
What This Case Means for the FCA Going Forward
Ultimately, the Wisconsin Bell decision reinforces that the government’s fight against fraud is not limited by rigid definitions. Instead, the emphasis is on substance over form, ensuring that any misrepresentation intended to secure public funds is subject to accountability. This ruling not only bolsters the enforcement of the FCA but also serves as a cautionary reminder for contractors and others dealing with government contracts to maintain utmost accuracy and transparency in their business dealings.
Barrett Johnston Martin & Garrison, PLLC, stays on top of the latest developments involving health care fraud and False Claims Act cases to represent whistleblowers in cases all over the country. If you have information or questions regarding a potential case of health care fraud, schedule a free and confidential consultation with our firm.
