Life after Bryan: intent under the anti-kickback law

In the past year, two courts have analyzed the proper standard of "willfulness" necessary to violate the anti-kickback law. At present, it appears that an intentional act, taken with knowledge that one is violating some law, is sufficient to violate the standard. It remains to be seen, however, whether the anti-kickback law will be deemed "highly technical," and thereby be violated only by one knowing that he is violating that particular statute. Moreover, the cases are not clear as to how close of nexus is required between the "knowingly violated" law and the anti-kickback law.