False Claims Act (FCA) with an International Spin: A Discussion with Christina Lehm, Partner, Nelson Mullins

Episode Date: October 7, 2026

Prevention can help avoid much bigger problems down the road. In this episode of Stark Integrity, host Bob Wade ("Captain Integrity") of Wade Health Law welcomes Christina Lehm, a partner at Nelson Mullins, for a practical discussion of the False Claims Act (FCA) with an international spin.

The conversation focuses on a straightforward compliance lesson: organizations should understand their exposure before a concern becomes a dispute. That is particularly important for international companies entering the U.S. market, where unfamiliar legal expectations can intersect with government money, internal reporting, and litigation risk.

Follow the Government Money

One of the episode’s clearest guideposts is to follow the government money. An organization cannot evaluate FCA risk effectively without understanding where government funds touch its operations and what statements, submissions, or decisions are connected to those funds.

The practical point is not to begin with labels or assumptions. Begin with the flow of money and the underlying facts. Map the relevant business processes, identify who is responsible for them, and determine where legal and compliance review belongs. For healthcare leaders, counsel, and compliance officers, that disciplined approach creates a clearer picture of risk and a stronger basis for action.

Take Internal Concerns Seriously—and Act Early

Bob and Christina also emphasize the importance of taking internal concerns seriously. A report from an employee or other stakeholder should not be dismissed because it appears incomplete, inconvenient, or difficult to evaluate. It may be the organization’s earliest opportunity to understand and address a developing problem.

Acting early means using an appropriate review process, involving the right personnel, and documenting the organization’s response. The objective is not to prejudge the issue. It is to gather facts, assess the concern carefully, and decide what corrective action, if any, is warranted. Delay can narrow options; prompt attention can preserve them.

Litigation Readiness Is Part of Business Strategy

Another key theme is that litigation readiness should be treated as part of business strategy—not merely as a reaction after a claim is filed. Organizations are better positioned when responsibilities are clear, escalation channels are established, and important decisions can be explained through reliable records.

That mindset supports both compliance and operational resilience. It allows leadership to respond more deliberately when questions arise and helps ensure that legal considerations are integrated into business planning rather than added after the fact.

An International Company Still Needs a U.S. Compliance Lens

For international companies entering the United States, the episode offers an important warning: a successful approach in another market may not fully address U.S. FCA risk. Expansion plans should include a focused assessment of how the company will interact with government money and how concerns will be reported, escalated, and reviewed.

The best time to establish that framework is before operations accelerate. Early planning can help align leadership, legal counsel, and compliance personnel around a shared process. It also reinforces the broader message of the episode: prevention is a business advantage, not simply a legal expense.

Final Thoughts

This episode brings an international perspective to a distinctly practical FCA discussion. Follow the government money. Listen when concerns are raised. Act before a manageable issue becomes a larger one. Treat readiness as part of strategy.

Captain Integrity’s compass points in a familiar direction: thoughtful prevention, disciplined review, and timely action give organizations the strongest foundation for navigating risk—whether they are established U.S. healthcare companies or international businesses entering the market.

Click here to listen to this Stark Integrity Podcast Episode: https://podcasts.apple.com/us/podcast/false-claims-act-fca-with-an-international/id1588939373?i=1000793578717