On March 8, 2022, the U.S. Department of Justice (DOJ) announced a $930,000 settlement with Comprehensive Health Services, LLC (CHS) for alleged violations of the False Claims Act (FCA). This settlement marks DOJ’s first resolution of an FCA enforcement action involving cyber fraud after launching its Civil Cyber-Fraud Initiative in October 2021, signaling DOJ’s eagerness to emphasize its commitment to combatting cybersecurity violations and misrepresentations.
The DOJ alleged that, between 2012 and 2019, CHS violated the FCA by falsely representing to the U.S. Department of State and U.S. Air Force that it had complied with contractual obligations in connection with its agreement to provide medical and data record services at State Department and Air Force facilities in Iraq and Afghanistan. Specifically, DOJ alleged that CHS stored patients’ protected health information (PHI) and confidential identifying information on an electronic medical record (EMR) system that was, at times, unsecured, in violation of express contractual requirements. CHS also allegedly failed to remediate the cybersecurity failures after its employees raised concerns that confidential medical and identifying information had inappropriately been stored and saved outside of the EMR system.
Further, DOJ asserted that CHS had falsely represented to the State Department and Air Force that the controlled substances it supplied to patients pursuant to the contracts were approved by the U.S. Food and Drug...
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