The U.S. Department of Justice (DOJ) announced the creation of the Civil Rights Fraud Initiative in a Memorandum issued on May 19, 2025. According to the Memorandum, the Initiative is an enforcement effort that will use the...more
6/2/2025
/ Affirmative Action ,
Colleges ,
Department of Justice (DOJ) ,
Diversity and Inclusion Standards (D&I) ,
Educational Institutions ,
Enforcement Actions ,
Executive Orders ,
False Claims Act (FCA) ,
Federal Contractors ,
Federal Funding ,
Reverse Discrimination ,
Trump Administration ,
Universities ,
Whistleblowers
On January 15, 2025, the U.S. Department of Justice (DOJ) announced $2.9 billion in total False Claims Act (FCA) recoveries for FY 2024, a slight increase from 2023. In addition to growing recoveries, DOJ announced a new...more
1/20/2025
/ Coronavirus/COVID-19 ,
Cybersecurity ,
Cybersecurity Maturity Model Certification (CMMC) ,
Department of Defense (DOD) ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Fraud ,
Healthcare Fraud ,
Medicare ,
Medicare Advantage ,
Opioid ,
Paycheck Protection Program (PPP) ,
Qui Tam ,
Whistleblowers
The Department of Justice (DOJ) secured another win for its Civil Cyber-Fraud Initiative last week when it resolved a False Claims Act (FCA) action[1] alleging Pennsylvania State University (Penn State) failed to comply with...more
10/29/2024
/ Chief Information Officers (CIO) ,
Compliance ,
Corporate Counsel ,
Cybersecurity ,
Data Breach ,
Department of Defense (DOD) ,
Department of Justice (DOJ) ,
DFARS ,
False Claims Act (FCA) ,
Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
FedRAMP ,
Information Technology ,
Medicare ,
NASA
Years from now, might we cite a recent Middle District of Florida decision as the beginning of the end of the False Claim Act’s (FCA) qui tam provision in its current form? In granting the defendants’ motion for judgment on...more
10/11/2024
/ Department of Justice (DOJ) ,
Executive Powers ,
False Claims Act (FCA) ,
Federal Contractors ,
Healthcare Fraud ,
Medicare ,
Private Actors ,
Qui Tam ,
Relators ,
United States ex rel Polansky v Executive Health Resources Inc ,
Whistleblowers
On August 1, 2024, the U.S. Department of Justice (DOJ) released details about its new Corporate Whistleblower Awards Pilot Program. As previewed by Deputy Attorney General Lisa Monaco in March, individuals (not entities) who...more
The more things change, the more things stay the same. For years, U.S. Department of Justice (DOJ) leadership has used the ABA National Institute on White Collar Crime and other major conferences to highlight enforcement...more
3/11/2024
/ Artificial Intelligence ,
CFTC ,
Compliance ,
Department of Justice (DOJ) ,
Ethics ,
False Claims Act (FCA) ,
Federal Contractors ,
Foreign Corrupt Practices Act (FCPA) ,
Securities and Exchange Commission (SEC) ,
Voluntary Disclosure ,
Whistleblowers ,
White Collar Crimes
WHAT: On June 16, 2023, the U.S. Supreme Court ruled 8–1 that the Government has broad authority to intervene and dismiss False Claims Act (FCA) suits litigated by relators. U.S. ex rel. Polansky v. Executive Health Resources...more
On February 7, 2023, the Department of Justice (DOJ) announced that FY 2022 yielded just $2.2 billion in spoils from False Claims Act (FCA) judgments and settlements—the smallest haul since 2008 and a precipitous drop from...more
On February 1, the U.S. Department of Justice (DOJ) announced the second-largest annual total recoveries in the history of the False Claims Act (FCA)—$5.6 billion—for FY 2021 (October 2020 – September 2021)...more
2/3/2022
/ Cybersecurity ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Billing ,
False Claims Act (FCA) ,
Federal Contractors ,
Fraud ,
Health Care Providers ,
Healthcare Fraud ,
Information Technology ,
Kickbacks ,
Medicare ,
Misrepresentation ,
Opioid ,
Qui Tam ,
Unnecessary Medical Procedures ,
Whistleblowers
After a wave of defense-friendly policies under the Trump Administration, the U.S. Department of Justice (DOJ) has reversed course on agency guidance and its buyer’s remorse will enable its attorneys to try once again to...more
On Friday, August 13, a D.C. Circuit panel unanimously unwound UnitedHealth Group’s (UnitedHealth) successful challenge to the Medicare Advantage Overpayment Rule, determining that the Centers for Medicare and Medicaid...more
It should surprise absolutely no one that “falsity” is a core element of the False Claims Act – it is the FALSE Claims Act, after all. However, it may come as a surprise that there is substantial disagreement over what...more
The U.S. Department of Justice (DOJ) Civil Division has published new Guidance on how it will evaluate the assertions of parties who claim they are unable to pay judgments or penalties in False Claims Act (FCA) and other...more