Mealey's (June 16, 2015, 10:30 AM EDT) -- CLEVELAND — The pre-Patient Protection and Affordable Care Act (ACA) public disclosure standard applies to an False Claims Act (FCA) action filed after the law’s passage but alleging conduct before its passage, a federal judge in Ohio held March 24 (United States of America, ex rel., Alan Moore and Teresa Berkshire v. Pennrose Properties LLC and Kapp Construction Company Inc., No. 11-121, S.D. Ohio; 2015 U.S. Dist. LEXIS 37373)....