June 16 marks one year since the birth of a bouncing baby fraud theory—implied certification—which attaches False Claims Act liability to contractors that request payments while concealing the failure to comply with critical requirements.

Such as, perhaps the use of air base security guards that can’t pass marksmanship tests in United States v. Triple Canopy Inc.

Although the doctrine of implied certification in the still new Supreme Court decision, Universal Health Servs., Inc. v. United States ex rel. Escobar, has grown over the past 12 months, numerous questions still need answers before implied certification can walk steadily on...