request contained the implied certification that it was appropriate for the Government to pay for the services rendered. However, the above-mentioned schemes rendered the services non-reimbursable due to violations of the AKS. To provide additional background for the Government’s allegations, the AKS, in relevant part, makes it illegal to “knowingly and willfully” arrange for or provide remuneration as an inducement for federal program business, 42 U.S.C. § 1320a-7b(b). Any claim tainted by an AKS violation constitutes a false or fraudulent claim. 42 U.S.C. 1320a-7b(g) (“[A] claim that includes items or services resulting from a violation of [the AKS] constitutes a false or fraudulent claim for purposes of [the FCA.]”); see United States v. Rogan, 517 F.3d 449, 452-53 (7th Cir. 2008) (<HOLDING>); see also U.S. ex rel. Drakeford v. Tuomey,
holding that false arrest and false imprisonment claim were not duplicative holding statute imposing criminal sanctions for deliberately false statements submitted to federal agency even without a showing that defendant knew they were being submitted to the federal government did not constitute a trap for the unwary holding that all claims submitted by defendant were false because they were acquired by kickback holding that tort claims were arbitrable because they arose out of and were related to contract holding that the defendant contractor violated 18 usc  286  a companion statute to the criminal fca  because his claims were false when submitted even though the false claims were ultimately irrelevant to the total amount paid by the government to the contractor