Nimish discusses the options available to maintain anonymity, from filing under a pseudonym to using an incorporated entity, and explains the limits of each approach. He also examines how the outcome of a case, such as settlement, litigation, or dismissal, can affect a whistleblower’s ability to remain anonymous, and highlights federal whistleblower programs, including those administered by the SEC, IRS, and CFTC, where anonymity protections may be stronger. While no option guarantees complete anonymity, these strategies can be effective depending on the circumstances.

To read the full article, visit The Anti-Fraud Coalition’s website.

About Nimish R. Desai

A partner in Lieff Cabraser’s San Francisco office, Nimish R. Desai specializes in False Claims Act, class action, and environmental torts, and has helped secure over a billion dollar in settlements through his cases. He has been recognized as a Super Lawyer each year from 2013-2025 and has been repeatedly named to The Best Lawyers in America list in the field of Qui Tam Law.

Nimish currently serves as Chair of the Education Committee for The Anti-Fraud Coalition, the preeminent national whistleblower law organization, and regularly presents to national conferences on FCA topics. In his False Claims Act practice, he has represented whistleblower clients in the healthcare, military contracting, mortgage, and securities industries. In addition to managing numerous under seal matters, Nimish has litigated and won notable cases, including obtaining a $71 million settlement in a case alleging that a health plan and prominent hospitals defrauded the California and the United States of Medicaid funds by allegedly misrepresenting the plans’ medical loss ratio (MLR), and winning a $46 million false billing case settlement from one of California’s largest hospital systems.

“We are proud to represent whistleblowers—people who take their ethical obligations very seriously and who are often in the best position to observe fraud on taxpayers,” noted Lieff Cabraser partner Rachel Geman, who represents plaintiffs in the case. “We are especially appreciative of our relator’s efforts to maintain cybersecurity and courageous willingness to step forward when problems arose.”

Read more about Lieff Cabraser’s False Claims Act settlement with Raytheon on the DOJ’s website.

About Rachel Geman

Rachel Geman is a partner in Lieff Cabraser’s New York office and the Chair of the firm’s False Claims/Qui Tam practice group. Her practice is dedicated to complex class action and False Claims Act matters, with present and recent leadership appointments in a variety of matters from copyright to medical monitoring to forced labor. Rachel is a community mediator and a mom to two teenagers.

On Tuesday, April 8, 2025, Lieff Cabraser partner Ed Baker will speak on a panel at AAPC HealthCon, joining Dr. Khush Singh and Colleen Gianatosio on “Bad, Better, Best Practices: Avoiding FCA Liability for False or Invalid HCC Diagnoses from HRAs.”

On Wednesday, April 9, 2025, Ed will join Stephanie Allard for a discussion on “Your Risk of False Claims Act Violations When Filing Medicare Advantage Claims.” Learn more online at the event website.

About Edward Baker

A partner in Lieff Cabraser’s New York office, Edward Baker previously served as an Assistant U.S. Attorney in the Eastern District of California, where he was the Civil Healthcare Fraud Coordinator, as well as the Elder Justice Coordinator, within the Affirmative Civil Enforcement practice group. As an AUSA, Mr. Baker investigated numerous FCA cases, including allegations against physicians for medically unnecessary procedures, pharmacies for kickbacks to nursing homes, defense contractors and federal grant recipients for fraudulent billing, and hospitals for up-coding. He was the lead attorney for the United States in an FCA settlement against a group of Fresno cardiologists for performing medically unnecessary nuclear scans, and in a qui tam settlement against Omnicare, Inc., a national long-term care pharmacy, for improperly submitting claims for prescription drugs dispensed to patients in skilled nursing facilities. He worked closely with criminal prosecutors to enhance the district’s parallel proceedings practice and coordinated regular meetings of the EDCA Healthcare Fraud Task Force.

Prior to serving as an AUSA, Mr. Baker was an Assistant Attorney General for the State of Vermont, where he was the Director of the Medicaid Fraud and Residential Abuse Unit. He was a member of the litigation table team for thirty-six states in a qui tam lawsuit against Wyeth and Pfizer for Medicaid pharmaceutical “best price” violations that ultimately resulted in a $785 million settlement. He also laid the groundwork for the enactment of the Vermont False Claims Act and held leadership positions within the National Association of Medicaid Fraud Control Units.

(Qui tam is a Latin phrase that means “who sues on behalf of the king as well as for himself”. It’s used to describe a legal action where a private citizen, called a qui tam relator, sues on behalf of the United States government against a person or company that has defrauded the government.)

The distinguished panelists include:

• Jonodev Chaudhuri: Principal at Chaudhuri Law, Ambassador for the Muscogee Creek Nation, former Chairman of the National Indian Gaming Commission, and Senior Counselor to the Assistant Secretary of Indian Affairs at the U.S. Department of the Interior.
• Perrin Rynders: Partner at Varnum Law, who has represented the Saginaw Chippewa Tribe against BCBS Michigan for ERISA/Michigan FCA violations.

The event is free, and open to the public. For more details and to register, visit the FBA’s website.

About Edward Baker

Edward Baker is Of Counsel at Lieff Cabraser Heimann & Bernstein, LLP. He previously served as an Assistant U.S. Attorney in the Eastern District of California, where he was the Civil Healthcare Fraud Coordinator, as well as the Elder Justice Coordinator, within the Affirmative Civil Enforcement practice group. As an AUSA, Mr. Baker investigated numerous FCA cases, including allegations against physicians for medically unnecessary procedures, pharmacies for kickbacks to nursing homes, defense contractors and federal grant recipients for fraudulent billing, and hospitals for up-coding. He was the lead attorney for the United States in an FCA settlement against a group of Fresno cardiologists for performing medically unnecessary nuclear scans, and in a qui tam settlement against Omnicare, Inc., a national long-term care pharmacy, for improperly submitting claims for prescription drugs dispensed to patients in skilled nursing facilities. He worked closely with criminal prosecutors to enhance the district’s parallel proceedings practice and coordinated regular meetings of the EDCA Healthcare Fraud Task Force.

Prior to serving as an AUSA, Mr. Baker was an Assistant Attorney General for the State of Vermont, where he was the Director of the Medicaid Fraud and Residential Abuse Unit. He was a member of the litigation table team for thirty-six states in a qui tam lawsuit against Wyeth and Pfizer for Medicaid pharmaceutical “best price” violations that ultimately resulted in a $785 million settlement. He also laid the groundwork for the enactment of the Vermont False Claims Act and held leadership positions within the National Association of Medicaid Fraud Control Units.

About Emily Harwell

Emily Harwell is an associate in Lieff Cabraser’s New York office. She works in all areas of the firm’s practice, with a particular focus on and interest in representing tribes and tribal governments as plaintiffs.

Ms. Harwell grew up on the Sac and Fox Reservation in Oklahoma. She is a member of the Mvskoke (Muscogee) Creek Nation of Oklahoma. She graduated from Cornell Law School in 2022. While in law school, she served as Executive Editor for the Cornell Journal of Law & Public Policy and clerked at the Native American Rights Fund (“NARF”). As a clerk, Ms. Harwell focused on Native American voting rights litigation against state governments.

The AHLA’S Annual Meeting will be held in-person only and will provide attendees with the most current information and in-depth analysis on a myriad of issues facing health care clients and institutions, including practical solutions for addressing legal, regulatory, and operational issues facing the health care industry.

For more information and to view the full program agenda, visit the AHLA’s website.

About Edward Baker

Edward Baker is Of Counsel at Lieff Cabraser Heimann & Bernstein, LLP. He previously served as an Assistant U.S. Attorney in the Eastern District of California, where he was the Civil Healthcare Fraud Coordinator, as well as the Elder Justice Coordinator, within the Affirmative Civil Enforcement practice group. As an AUSA, Mr. Baker investigated numerous FCA cases, including allegations against physicians for medically unnecessary procedures, pharmacies for kickbacks to nursing homes, defense contractors and federal grant recipients for fraudulent billing, and hospitals for up-coding. He was the lead attorney for the United States in an FCA settlement against a group of Fresno cardiologists for performing medically unnecessary nuclear scans, and in a qui tam settlement against Omnicare, Inc., a national long-term care pharmacy, for improperly submitting claims for prescription drugs dispensed to patients in skilled nursing facilities. He worked closely with criminal prosecutors to enhance the district’s parallel proceedings practice and coordinated regular meetings of the EDCA Healthcare Fraud Task Force.

Prior to serving as an AUSA, Mr. Baker was an Assistant Attorney General for the State of Vermont, where he was the Director of the Medicaid Fraud and Residential Abuse Unit. He was a member of the litigation table team for 36 states in a qui tam lawsuit against Wyeth and Pfizer for Medicaid pharmaceutical “best price” violations that ultimately resulted in a $785 million settlement. He also laid the groundwork for the enactment of the Vermont False Claims Act and held leadership positions within the National Association of Medicaid Fraud Control Units.

Whistleblowers have long been unsung heroes in the fight against corruption, injustice, and wrongdoing. A recent Delray Beach case related to contaminated water systems in Florida illustrates the essential role whistleblowers play in upholding the public’s right to safety and transparency, and the courage required to stand up against powerful institutions.

In this case, Christine Ferrigan, a former Delray Beach Industrial Pretreatment Inspector, exposed years of poor water management and secured an $818,500 personal reward in addition to finally obtaining water quality improvements for Delray Beach.

For years, Delray Beach struggled with contaminated drinking water due to allegedly inadequate management by the city. Ferrigan’s whistleblowing efforts led to the city paying a $1 million fine, following an investigation confirming that partially treated reclaimed water had improperly been mixed with drinking water supplies. Ms. Ferrigan’s determination and courage to come forward ultimately resulted in the exposure of dangerous corruption and the restoration of public health for thousands.

Whistleblowers like Ms. Ferrigan are critical to promoting justice and making our world a better, safer place. They challenge deception, demand accountability, and safeguard the interests of the public. Often, their actions save lives and prevent further harm to the environment and our communities.

It is imperative for people with knowledge of wrongdoing to take a stand, as whistleblowers form the first line of defense against corruption and abuse. Their actions ensure that governments, organizations, and corporations are held accountable for their actions, protecting the rights and wellbeing of citizens. And the laws of the U.S. support and encourage this noble behavior by providing for cash incentives and rewards for whistleblowers who successfully expose corruption, fraud, and actions that are dangerous to all of us.

“The people of Delray Beach, and people everywhere, deserve clean water and to know when their health is at risk,” noted Ferrigan. “Individuals have the power to speak up and make a difference. By understanding and utilizing legal protections, potential whistleblowers can find the courage to come forward and contribute to creating a safer and more just society.”

About Lieff Cabraser’s Whistleblower Law Practice

Lieff Cabraser represents whistleblowers who uncover fraud on the government in a wide range of Qui Tam / False Claims Act cases, including medicare and healthcare fraud, defense contractor fraud, securities and financial fraud, insurance fraud, and many other false claims.

Lieff Cabraser’s successes in False Claims Act cases include helping former University of Phoenix enrollment counselors receive a portion of a $78.5 million settlement, the largest settlement ever in a qui tam case involving the U.S. Department of Education. The complaint alleged that the University of Phoenix defrauded the Department of Education by obtaining federal student loan and Pell Grant monies based on false statements of compliance with the Higher Education Act.

Lieff Cabraser also successfully represented the whistleblower and the California cities, counties, and school districts that intervened in a false claims lawsuit against Office Depot. Office Depot promised in the U.S. Communities contract to sell office supplies at its best governmental pricing nationwide, but repeatedly failed to give most of its California governmental customers the lowest price it was offering other governmental customers. A California Superior Court approved a $77.5 million settlement of the case.

For more information or to talk to us about a fraud you have uncovered, click here.

August 19, 2022, San Francisco–(BUSINESSWIRE)–The law firm of Lieff Cabraser Heimann & Bernstein, LLP announces a $70.7 million settlement of a False Claims Act whistleblower lawsuit against Gold Coast Health Plan and certain “favored” medical providers in California, in which Relators alleged that the defendants knowingly misused Medi-Cal funds they received in 2014 and 2015 for newly-enrolled adult Medi-Cal patients under the Affordable Care Act.

“Blowing the whistle on those defrauding the government is critically important,” stated Lieff Cabraser partner Robert J. Nelson, who represented the whistleblowers in the case, “and often requires extreme courage and commitment, especially as here, where it took seven years from the time of the original whistleblowing to the achievement of these substantial, meaningful settlements.”

Under “medical loss ratio” rules, Gold Coast was required to return to the government a certain percentage of monies that it did not ultimately use on health care for this Adult Expansion population. This mechanism allowed the government to adequately fund care for this newly-insured population knowing that any excess amounts would be returned. Instead of returning the funds to the government, relators alleged that Gold Coast distributed a large portion of it to favored providers for so-called “additional services,” which Relators alleged were not actually provided or were duplicative of services for which the providers had already been compensated. Relators further alleged that although Gold Coast claimed it would seek documentation from the providers to justify the payments for these “additional services,” it largely ignored that requirement, and in fact calculated the payments to providers before any documentation of services was provided.

As a result of settlements negotiated with Gold Coast and the favored providers, Gold Coast will pay $17.2 million to the United States and the State of California. The providers who sought and received these allegedly illegal payments – Ventura County Medical Center, Dignity Health, and Clinicas del Camino Real Inc. – will pay an additional $53.5 million, the balance of the total $70.7 million settlement.  The settlement was first made public by the United States Department of Justice and the California Attorney General on August 18, 2022. Lieff Cabraser represented the whistleblowers along with co-counsel Marc Reich at Reich Radcliffe & Hoover LLP.

“False Claims Act violations like those in this lawsuit harm not just the government, but also the patients and providers who rely on these funds to obtain and provide care, and the taxpayers who fund the system,” noted Lieff Cabraser partner Nimish R. Desai, who also represents the plaintiffs-relators in the case. “These extraordinary and extremely hard-won settlements, and the relief they bring, are a huge win for all of us.”

Contemporaneous with the False Claims Act settlement, the U.S. Department of Health and Human Services agreed to release its right to exclude Gold Coast and Ventura in exchange for their agreements to enter into five-year Corporate Integrity Agreements (CIAs). The CIAs require, among other things, that Gold Coast and Ventura County each implement centralized risk assessment programs as part of their compliance programs and each hire an Independent Review Organization to complete annual reviews.

For more information, visit https://lieffcabraser.com/false-claims-act/gold-coast/

Source/Contact

Robert J. Nelson/Nimish Desai
Lieff Cabraser Heimann & Bernstein, LLP
rnelson@lchb.com
415 956-1000

In a press release issued today, the U.S. Attorney’s office has announced that the United States filed and settled a civil fraud lawsuit brought by Lieff Cabraser and co-counsel against New York City healthcare provider The Door. The complaint alleges that The Door violated the False Claims Act by fraudulently overreporting the number of visits to its healthcare facility.  This overreporting resulted in The Door receiving excessive funding from the Indigent Care Pool, a program funded by both the federal government and New York State intended to reimburse certain healthcare providers for uncompensated care rendered to low-income New Yorkers.

“Through its misconduct, The Door received an excessive share of this funding at the expense of other healthcare providers that were similarly trying to provide services to low-income New Yorkers, and has now been held to account.”

— U.S. Attorney Damian Williams

Under the settlement, approved by U.S. District Judge Alvin K. Hellerstein of the Southern District of New York, The Door will pay $2,725,514.51 to the United States and has admitted and accepted responsibility for conduct alleged by the Government in the Complaint as further described below.  The Door has also agreed to pay $10,222,297.89 to the State of New York to resolve the State’s claims, for a total recovery of $12,947,812.40.

U.S. Attorney Damian Williams said: “This Office will remain vigilant in protecting public funds that are designated to help low-income New Yorkers.  The Indigent Care Pool is a limited source of funding meant to be shared among healthcare providers throughout New York State in order to further the goal of providing healthcare to all who need it.  Through its misconduct, The Door received an excessive share of this funding at the expense of other healthcare providers that were similarly trying to provide services to low-income New Yorkers, and has now been held to account.”

To view the full press release, visit the U.S. Department of Justice website.