O.C.G.A.

O.C.G.A. § 49-4-168 (2019)

Definitions

✓ O.C.G.A. — 2019 edition (Public.Resource.Org Release 73)
Code text and O.C.G.A. statutory annotations on this page reflect the 2019 Official Code of Georgia Annotated (Public.Resource.Org Release 73, 2019-08-21; public domain per Georgia v. Public.Resource.Org, 2020). The Syfert case-law annotations in Notes of Decisions, below, are current.
Find cases: SyfertCases citing this section GA-LEGlegis.ga.gov (official) JustiaJustia CornellLII Search CasesGoogle Scholar

As used in this article, the term: (1) “Claim” includes any request or demand, whether under a contract or otherwise, for money or property, whether or not the Georgia Medicaid program or this state has title to such money or property, which is made to the Georgia Medicaid program, to any officer, employee, fiscal intermediary, grantee, agent, or contractor of the Georgia Medicaid program, or to other persons or entities if it results in payments by the Georgia Medicaid program, if the Georgia Medicaid program provides, has provided, or will provide any portion of the money or property requested or demanded; if the Georgia Medicaid program will reimburse the contractor, grantee, or other recipient for any portion of the money or property requested or demanded; or if the money or property is to be spent or used on behalf of or to advance the Georgia Medicaid program. A claim includes a request or demand made orally, in writing, electronically, or magnetically. Each claim may be treated as a separate claim. (2) “Knowing” and “knowingly” require no proof of specific intent to defraud and mean that a person, with respect to information:

(A) Has actual knowledge of the information; (B) Acts in deliberate ignorance of the truth or falsity of the information; or (C) Acts in reckless disregard of the truth or falsity of the information. (3) “Material” means having a natural tendency to influence, or be capable of influencing, the payment or receipt of money or property. (4) “Obligation” means an established duty, whether or not fixed, arising from an express or implied contractual, grantor-grantee, or licensor-licensee relationship, from a fee based or similar relationship, from statute or regulation, or from retention of any overpayment. (5) “Person” means any natural person, corporation, company, association, firm, partnership, society, joint-stock company, or any other entity with capacity to sue or be sued.

History

Code 1981, § 49-4-168, enacted by Ga. L. 2007, p. 355, § 3/HB 551; Ga. L. 2012, p. 127, § 2-1/HB 822; Ga. L. 2013, p. 141, § 49/HB 79.

Annotations

Cross references. Georgia Taxpayer Protection Against False Claims Act, § 23-3-120 et seq.

Law reviews. For article, “A ‘False Claims Act’ Is Finally Enacted in Georgia: What Georgia Lawyers Should Know About the ‘State False Medicaid Claims Act’,” see 13 Ga. St. B.J. 12 (2007).

JUDICIAL DECISIONS Suit barred by res judicata. - Dismissal of the plaintiffs’ suit brought under the Georgia False Medicaid Claims Act, O.C.G.A. § 49-4-168 et seq., was affirmed because the suit was barred by res judicta based on an earlier-filed federal suit against the same pharmaceutical companies for similar claims. Jordan v. State of Ga., 336 Ga. App. 345, 785 S.E.2d 27, 2016 Ga. App. LEXIS 176 (2016), cert. denied, No. S16C1269, 2016 Ga. LEXIS 503 (Ga. Sept. 6, 2016). Failure to state claim based on billing of patients. - In the plaintiff’s second amended complaint alleging four schemes that resulted in the presentation of false or fraudulent claims for payment

to Medicaid and PeachCare in violation of the Georgia False Medicaid Claims Act (GFMCA), O.C.G.A. § 49-4-168 et seq., the complaint failed to state a claim with regard to balance billing because that scheme related to the billing of patients, not the billing of the Georgia Medicaid program as required to state a claim under the GFMCA; and the GFMCA did not provide civil liability for claims submitted to anyone other than the Georgia Medicaid program. Hill v. Bd. of Regents of the Univ. Sys. of Ga., 351 Ga. App. 455, 829 S.E.2d 193, 2019 Ga. App. LEXIS 423 (2019), cert. denied, No. S19C1531, 2020 Ga. LEXIS 164 (Ga. Feb. 28, 2020).

RESEARCH REFERENCES ALR. Liability for trespass or nuisance in hydraulic fracturing, hydro-fracturing, or hydro-fracking, 41 A.L.R.7th Art. 1. Measure and elements of damages under State False Claims Acts, 41 A.L.R.7th Art. 2.

Recognition and application of tort of negligent assault and battery and indirect battery, 41 A.L.R.7th Art. 8. Reverse false claims under State False Claims Act, 46 A.L.R.7th Art. 2.

Notes of Decisions
Cited in 14 cases (7 in the last 5 years), 2011–2025 · leading case: Hill v. Bd. of Regents of the Univ. Sys. of Georgia Et Al., 829 S.E.2d 193 (Ga. Ct. App. 2019).
Hill v. Bd. of Regents of the Univ. Sys. of Georgia Et Al., 829 S.E.2d 193 (Ga. Ct. App. 2019). · cites it 8× “Jennifer Hill filed this qui tam action to recover damages and civil penalties on behalf of the State of Georgia under the Georgia False Medicaid Claims Act, OCGA § 49-4-168, et seq. (the "GFMCA"), and for damages under the GFMCA and the Georgia Whistleblower Act, OCGA § 45-1-4…”
New York v. Amgen Inc., 652 F.3d 103 (1st Cir. 2011). · cites it 2× “Gov’t Code §§ 12650 to 12656; Georgia State False Medicaid Claims Act, Ga.Code Ann. §§ 49-4-168 to 49-4-168.6; Illinois Whistleblower Reward and Protection Act, 5 740 111.”
United States ex rel. Dickson v. Bristol-Meyers Squibb Co., 123 F. Supp. 3d 584 (D.N.J. 2015). “19; (Count 13) Georgia False Medicaid Claims Act, Ga.Code Ann. § 49-4-168 et seq.; (Count 14) Indiana State False Claims and Whistleblowers Protection Act; IndiCode Ann.”
Whitaker Farms, LLC v. Fitzgerald Fruit Farms, LLC, 908 S.E.2d 531 (Ga. 2024). “” See OCGA §§ 23-3-120, OCGA § 49-4-168. Moreover, the statute authorizing the recovery of punitive damages requires that an “award of punitive damages must be specifically prayed for.”
Steven Jordan v. State of Georgia, 785 S.E.2d 27 (Ga. Ct. App. 2016). · cites it 2× “Eight individuals brought suit on behalf of the State of Georgia against three related pharmaceutical companies under the Georgia False Medicaid Claims Act (GFMCA), OCGA § 49-4-168 et seq. 1 The plaintiffs alleged that the companies fraudulently obtained millions of dollars in…”
United States ex rel. Bierman v. Orthofix Int'l, N.V., 113 F. Supp. 3d 414 (D. Mass. 2015). “081-092 ; the Georgia State False Medicaid Claims Act, Ga.Code Ann. §§ 49-4-168 et seq.; the Hawaii False Claims Act, Haw.”
John C. Lipman v. State of Georgia (Ga. Ct. App. 2023). · cites it 4× “In this action under the Georgia False Medicaid Claims Act (“GFMCA”), OCGA §§ 49-4-168 to 49-4-168.6, the defendants appeal from the trial court’s denial of their motion to dismiss.”
Zediker v. Orthogeorgia (M.D. Ga. 2019). · cites it 2× “After the Government (the United States and the State of Georgia), intervened with its own complaint and some Defendants were dismissed, the Relator, the Government, and Defendant OrthoGeorgia2 reached a $760,000.00 settlement of the Government’s claims.”
Walthour (ex Rel) v. Middle Georgia Fam. Rehab LLC (M.D. Ga. 2022). · cites it 2× “Relator Walthour is a Georgia-licensed occupational therapist who worked at MGFR from February 2018 to May 2018, where he performed patient evaluations and provided occupational therapy services to patients.”
United States of Am. v. ApolloMD, Inc. (N.D. Ga. 2021). · cites it 2× “Count 5 alleges violations of the Georgia State False Medicaid Claims Act (O.C.G.A. § 49-4-168), and is not dismissed for the same reasoning elucidated supra in the discussion relating to Counts 1 and 2.”
United States of Am. v. Biogen Inc. (D. Mass. 2022). · cites it 2× “); Georgia ( Ga. Code Ann. §§ 49-4-168 , et seq.), Illinois (740 Ill.”
Gonite v. Unitedhealthcare of Georgia Inc (M.D. Ga. 2025). · cites it 2× “52) on the grounds that (1) the FCA is unconstitutional and (2) Gonite fails to state a claim.”
— 49-4-168(2) — 1 case
New York v. Amgen Inc., 652 F.3d 103 (1st Cir. 2011). “Gov’t Code §§ 12650 to 12656; Georgia State False Medicaid Claims Act, Ga.Code Ann. §§ 49-4-168 to 49-4-168.6; Illinois Whistleblower Reward and Protection Act, 5 740 111.”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.