Some key things to keep in mind for protecting yourself from a charge under the FCA include:
Carefully choose billing contractors. You will be held liable for any mistakes or scams contractors run when they submit claims on your behalf.
Aggressively supervise contractors and employees to ensure they are aware of and are following all government regulations regarding billing and claims.
Create policies to reward whistleblowers for reporting wrongdoing in-house.
Respond rapidly and appropriately once an offense is detected and act to prevent further wrongdoing.