HIGHER EDUCATION: AN APPROPRIATE REALM TO IMPOSE FALSE CLAIMS ACT LIABILITY UNDER THE POST-FORMATION IMPLIED FALSE CERTIFICATION THEORY.

The article focuses on whether or not educational institutions in the U.S. should be held liable under the Financial Conduct Authority for entering into a Program Participant Agreement with the government, and thereafter committing fraud. Topics include background of theory of liability; U.S. Supreme Court case Universal Health Services, Inc. v. United States ex rel. Escobar, which deals with implied false certification theory; and policy implications of implied certification.