SETTLEMENT AGREEMENTSettlement Agreement • September 12th, 2018
Contract Type FiledSeptember 12th, 2018This Settlement Agreement (“Agreement”) is entered into among (i) the United States of America, acting through the United States Department of Justice (“DOJ”) and on behalf of the Office of Inspector General (“OIG”) of the Department of Health and Human Services (“HHS”); the Centers for Medicare and Medicaid Services (“CMS”); the Defense Health Agency (“DHA”), acting on behalf of the TRICARE program, 10 U.S.C. §§ 1071-1110b (“TRICARE”); and the Office of Personnel Management (“OPM”), which administers the Federal Employees Health Benefits Program, 5 U.S.C. §§ 8901-8914 (“FEHBP”) (collectively, the “United States”); (ii) the Virginia Birth-Related Neurological Injury Compensation Program and its Board of Directors (the “Program”) and the Commonwealth of Virginia (“Virginia”), including the Department of Medical Assistance Services (“DMAS”) (collectively, “Virginia/DMAS”), and (iii) Relators Theodore Arven III and Veronica N. Arven (collectively, “Relators”) (the United States, Program,