I. Background Qui tam relator Steve Greenfield was an area vice president of Accredo Health Group, Inc., a specialty pharmacy that provides home care for patients with hemophilia, a rare blood-clotting disorder. Greenfield sued Accredo Health Group, along with its affiliates Medco Health Solutions, Inc. and Hemophilia Health Services, Inc. (collectively, the "Accredo defendants"), under the FCA, alleging that the Accredo defendants made donations to two charities – Hemophilia Services, Inc. (HSI), and Hemophilia Association of New Jersey (HANJ) – in order to induce the charities to recommend or refer their hemophiliac members to Accredo, in violation of the AKS. According to Greenfield, this alleged kickback scheme resulted in an FCA violation "because at least some of the referrals or recommendations were directed to Medicare beneficiaries and because Accredo falsely certified compliance with the [AKS] while submitting Medicare claims for payment."