Dr. Susan Nedza’s second amended qui tam complaint, or SAC, against American Imaging Management, called AIM, its owner, Anthem Inc., and 27 Medicare Advantage, or MA, plans relied on the “implied false certification” theory that was adopted for False Claims Act cases by the U.S. Supreme Court in Universal Health Services v. U.S. ex rel. Escobar, 136 S. Ct. 1989 (2016).Escobar’s rigorous materiality …