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The Latest On Statistical Sampling In FCA Cases

After waiting over a year to hear what the Fourth Circuit would say about statistical sampling in False Claims Act cases, the court of appeals recently chose to keep us in suspense. Despite initially granting the relators’...more

February 2017 Protest Roundup

In February 2017, the Government Accountability Office (GAO) publicly released notable decisions addressing (1) the effect of the temporary lapse in GAO’s civilian task order jurisdiction; (2) discussions, clarifications, and...more

DC Circuit Enforces Escobar’s Materiality Requirement

This week, the D.C. Circuit added to the post-Escobar, materiality jurisprudence with its opinion in United States ex rel. McBride v. Halliburton Co., No. 15-7144 (Feb. 17, 2017). In its decision, the court affirmed the...more

Universal Health: The Supreme Court Approves Implied Certification; Focus on Materiality Provides a Mixed Blessing to Defendants...

On June 16, 2016, a unanimous Supreme Court blessed the implied false certification theory of False Claims Act (FCA) liability, resolving a circuit split on the theory’s legitimacy. The Court held that implied certification...more

The Difficulty Of Challenging FCA Fine As Excessive

Last month, in U.S. ex rel. Drakeford v. Tuomey, No. 13-2219, (4th Cir. July 2, 2015), the Fourth Circuit affirmed a False Claims Act verdict against a nonprofit hospital in Sumter, South Carolina. In an area of the law where...more

OMB and Federal Agencies Publish Final Rule on Grants and Cooperative Agreements

On December 19, 2014, the White House Office of Management and Budget (OMB) and 28 federal agencies published in the Federal Register a consolidated interim final rule to implement OMB’s December 2013 final guidance on...more

Global Procurement Quarterly - Summer/Fall 2014

In This Issue: - Recent Trends in FCPA Enforcement – First Half of 2014 - Ukraine/Russia–Related Sanctions - New Executive Order Places Additional Reporting Obligations on Government Contractors and...more

World Bank Suspension and Debarment Report

On June 26, 2014, the World Bank’s Office of Suspension and Debarment (OSD) released its public report covering sanctions arising from World Bank-financed projects during OSD’s first six years of operation. The report...more

OMB Revises and Consolidates Rules Governing Most Federal Grants

In the final days of 2013, the White House Office of Management and Budget (OMB) released for publication long-awaited final guidance on administrative requirements, cost principles and audit requirements pertaining to...more

1/7/2014  /  Federal Grants , Funding , OMB
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