Dr. Smith has a private psychiatric medical practice that includes a large number of Medicare and Medicaid patients. Dr. Smith's wife serves as his practice manager and handles all third party billings. Dr. Smith knows virtually nothing about Medicare and Medicaid billing and relies entirely on his wife to process the claims, although he does sign the billing form attestations stating that the bills are truthful and accurate. If HHS charges him with violating the False Claims Act for bills which his practice submitted, can he refute responsibility for billing irregularities by claiming that he personally does not know the billing requirements? What would be the most appropriate practice with regarding to billing to governmental payors