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Circuit Comparison

How do the Third and Eighth Circuits analyze causation under the AKS? Summarize in a chart.
How do the Third and Eighth Circuits analyze causation under the AKS? Summarize in a chart.
Found 23 cases across 3d and 8th Circuits
Analyzed U.S. ex rel. Greenfield v. Medco Health Solutions, 880 F.3d 89 (3d Cir. 2018)
Analyzed U.S. v. Midwest Neurosurgeons, LLC, 42 F.4th 828 (8th Cir. 2022)

There is a clear circuit split. The Third Circuit rejected a but-for causation requirement, while the Eighth Circuit adopted one. Here is a comparison:

Third CircuitEighth Circuit
Causation standardNo but-for causation requiredBut-for causation required
Key phrasePatient must be "exposed to" an illegal referral"Resulting from" = but-for cause
What plaintiff must showA link between the AKS violation and a specific claim for reimbursementThat items or services would not have been included but for the kickback
Rejected standardsBut-for causation of patient’s subjective decision"Taint" or "contributing factor" tests
Key authorityGreenfield v. Medco, 880 F.3d 89 (3d Cir. 2018)U.S. v. Midwest Neurosurgeons, 42 F.4th 828 (8th Cir. 2022)

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