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News Item: A record $851 million was recovered from Medicaid providers due to abuse, fraud, and waste in 2013, New York Governor Andrew Cuomo announced on Monday, February 3. Read more here: http://www.governor.ny.gov/press/02032014-medicaid-recoveries.

Legal Ruling: In a case alleging that shipper DHL charged the Government for jet fuel surcharges on ground deliveries, the court held that the relator’s failure to comply with a 180-day notice rule for administrative actions before the Surface Transportation Board (STB) did not bar a shipping-rate challenge before a federal court when brought pursuant to the FCA. The district court had concluded that it did and dismissed the action. Without deciding how the 180-day rule applies to other kinds of suits brought in court, the Second Circuit vacated on the ground that the 180-day rule cannot apply to a qui tam action under the FCA. The lawsuit is captioned United States v. DHL Express (USA), Inc., 2014 U.S. App. LEXIS 2164 (2d Cir. N.Y. Feb. 5, 2014).