In the coming months, the Supreme Court will render a landmark decision and determine the viability of the “implied certification” theory of legal falsity under the False Claims Act. The Supreme Court recently heard oral argument in this landmark case where the relators claim the defendant, Universal Health Services, presented false claims for payment under the “implied certification” theory. The case is before the Supreme Court on appeal from the First Circuit’s decision in United States ex rel. Escobar v. Universal Health Services, 780 F.3d 504 (1st Cir. 2015).