On March 26, the Trump administration issued another DEI-focused Executive Order (“EO”) requiring all federal agencies to incorporate new anti-DEI certifications in contracts, “contract-like instruments,” and subcontracts...more
Drug manufacturers participating in the Section 340B Drug Pricing Program now face a significant new litigation risk under the False Claims Act (“FCA”)....more
3/23/2026
/ AbbVie ,
AstraZeneca ,
Covered Entities ,
Drug Pricing ,
False Claims Act (FCA) ,
Health Care Providers ,
Healthcare Facilities ,
Healthcare Fraud ,
Hospitals ,
HRSA ,
Medicaid ,
Medicare ,
Novartis ,
Pharmaceutical Industry ,
Qui Tam ,
Sanofi ,
Section 340B
On March 16, 2026, President Trump issued an Executive Order titled “Establishing the Task Force to Eliminate Fraud” (the “Order”), which creates an interagency task force to identify, investigate, and recoup losses from...more
3/23/2026
/ Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Priorities ,
Executive Orders ,
False Claims Act (FCA) ,
Federal Contractors ,
Federal Funding ,
Fraud ,
Government Agencies ,
Joint Task Force ,
Qui Tam ,
Trump Administration ,
Whistleblowers
This is the sixth post in the Dorsey FCANow Blog’s FCA Basics Series covering the fundamentals of the False Claims Act (“FCA”), outlining FCA procedure and highlighting key facets of FCA practice. Today’s post discusses...more
3/10/2026
/ Administrative Procedure ,
Administrative Proceedings ,
Civil Investigation Demand ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
Disclosure Requirements ,
Enforcement Actions ,
False Claims Act (FCA) ,
Government Investigations ,
Litigation Strategies ,
Qui Tam ,
Self-Disclosure Requirements ,
Subpoenas ,
Voluntary Disclosure ,
Whistleblowers
Deputy Assistant Attorney General Brenna Jenny reaffirmed DOJ’s commitment to targeting employment practices at organizations that receive federal funding with the False Claims Act during the Federal Bar Association’s annual...more
2/24/2026
/ Anti-Discrimination Policies ,
Corporate Counsel ,
Department of Justice (DOJ) ,
Diversity and Inclusion Standards (D&I) ,
Employment Discrimination ,
Enforcement Actions ,
False Claims Act (FCA) ,
Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
Federal Funding ,
Investigations ,
Qui Tam
This is the fifth post in the Dorsey FCANow Blog’s FCA Basics Series covering the fundamentals of the False Claims Act (“FCA”), outlining FCA procedure, and highlighting key facets of FCA practice. Today’s post covers the...more
2/18/2026
/ Anti-Kickback Statute ,
Criminal Liability ,
Damages ,
Eighth Amendment ,
False Claims Act (FCA) ,
Healthcare Fraud ,
Objective Falsity ,
Penalties ,
Qui Tam ,
Reverse False Claims ,
Statutory Violations ,
Whistleblowers
This is the sixth post in the Dorsey FCANow Blog’s FCA Basics Series covering the fundamentals of the False Claims Act (“FCA”), outlining FCA procedure, and highlighting key facets of FCA practice. Today’s post discusses a...more
This is the fourth post in the Dorsey FCANow Blog’s FCA Basics Series covering the fundamentals of the False Claims Act (“FCA”), outlining FCA procedure, and highlighting key facets of FCA practice. ...more
Recent SBA directives and statements by senior leaders suggest a fundamental shift in the viability and risk associated with the Small Business Administration’s Section 8(a) contracting program. Federal contractors who are...more
1/28/2026
/ 8(a) Program ,
Compliance ,
Diversity and Inclusion Standards (D&I) ,
Enforcement Actions ,
Executive Orders ,
False Claims Act (FCA) ,
Federal Contractors ,
New Guidance ,
Prime Contractor ,
Risk Management ,
SBA ,
Small Business ,
Subcontractors ,
Suspensions & Debarments ,
Trump Administration
The Department of Justice (DOJ) announced that False Claims Act (FCA) settlements and judgments surpassed $6.8 billion in FY 2025—the highest single-year total in FCA history....more
1/23/2026
/ Coronavirus/COVID-19 ,
Cybersecurity ,
Defense Sector ,
Department of Defense (DOD) ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Enforcement Statistics ,
False Claims Act (FCA) ,
Federal Contractors ,
Healthcare Fraud ,
Popular ,
Qui Tam ,
Settlement ,
Tariffs
This is the third post in the Dorsey FCANow Blog’s FCA Basics Series covering the fundamentals of the False Claims Act (“FCA”), outlining FCA procedure, and highlighting key facets of FCA practice. Today’s post introduces the...more
On December 12, 2025, the Eleventh Circuit heard oral arguments in United States ex rel. Zafirov v. Florida Medical Associates, an appeal challenging relators’ authority to bring claims under the qui tam provisions of the...more
12/17/2025
/ Appellate Courts ,
Appointments Clause ,
Constitutional Challenges ,
Department of Justice (DOJ) ,
False Claims Act (FCA) ,
Lucia v SEC ,
Oral Argument ,
Qui Tam ,
SCOTUS ,
Separation of Powers ,
Statutory Interpretation ,
Take Care Clause ,
Vesting
On Friday, December 5, the Small Business Administration (“SBA”) announced that it sent letters to all entities that participate in the SBA’s 8(a) Business Development Program—over 4,300 entities, per SBA—directing those 8(a)...more
12/12/2025
/ 8(a) Program ,
Department of Justice (DOJ) ,
Enforcement Actions ,
False Claims Act (FCA) ,
Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
Financial Records ,
Regulatory Requirements ,
Reporting Requirements ,
SBA ,
Small Business
Under the False Claims Act (FCA), private individuals—i.e. qui tam relators—file suit on behalf of the government against individuals or organizations, seeking to redress alleged frauds on the government. See 31 U.S.C. §...more
12/10/2025
/ Appeals ,
Appellate Courts ,
Appointments Clause ,
Article II ,
Constitutional Challenges ,
False Claims Act (FCA) ,
Fraud ,
Judicial Authority ,
Qui Tam ,
Relators ,
SCOTUS ,
Separation of Powers
This is the second post in the Dorsey FCANow Blog’s FCA Basics Series covering the fundamentals of the False Claims Act (“FCA”), outlining FCA procedure, and highlighting key facets of FCA practice. Today’s post introduces...more
The Trump Administration’s unprecedented terminations of federal contracts and grants have affected organizations seeking options and remedies. Universities, academic research institutions, federal contractors, and state and...more
11/19/2025
/ Administrative Procedure Act ,
Colleges ,
Contract Disputes ,
Contract Termination ,
Court of Federal Claims ,
Federal Contractors ,
Federal Grants ,
Government Agencies ,
Jurisdiction ,
Popular ,
Research Funding ,
Sovereign Immunity ,
State and Local Government ,
Trump Administration ,
Tucker Act ,
Universities
A recent decision by the U.S. District Court for the Northern District of California to reject a proposed $57 million settlement in a False Claims Act (FCA) litigation highlights the unique challenges and complexities that...more
11/13/2025
/ Breach of Contract ,
CERCLA ,
Consent Decrees ,
Contamination ,
Department of Justice (DOJ) ,
Environmental Litigation ,
False Claims Act (FCA) ,
Fraud ,
Judicial Authority ,
Public Health ,
Settlement ,
Site Remediation ,
Superfund ,
Whistleblowers
After fourteen years of litigation, United States ex rel. Schutte v. SuperValu, Inc. arrived at its likely end after the U.S. District Court for the Central District of Illinois rejected relators’ bid for a new trial after a...more
11/7/2025
/ False Claims Act (FCA) ,
Healthcare Fraud ,
Jury Trial ,
Jury Verdicts ,
Materiality ,
Medicaid ,
Medicare ,
Prescription Drugs ,
Qui Tam ,
Reimbursements ,
Relators ,
Scienter ,
SCOTUS ,
US ex rel Tracy Schutte et al v SuperValu Inc et al
The Cybersecurity Maturity Model Certification program for federal defense contracts and solicitations is moving out November 10, 2025. This is just the start....more
11/6/2025
/ Cybersecurity ,
Cybersecurity Maturity Model Certification (CMMC) ,
Department of Defense (DOD) ,
Department of Justice (DOJ) ,
DFARS ,
Enforcement Actions ,
False Claims Act (FCA) ,
Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
Regulatory Requirements ,
Risk Management
Dorsey’s FCANow Blog is kicking off a new series—FCA Basics. Over the coming months, the FCANow Blog will feature posts covering the fundamentals of the False Claims Act (“FCA”), outlining FCA procedure, and highlighting key...more
11/3/2025
/ False Claims Act (FCA) ,
Federal Contractors ,
Federal Funding ,
Fraud ,
Healthcare Fraud ,
Legal History ,
Medicaid ,
Medicare ,
Qui Tam ,
Reverse False Claims ,
Whistleblowers
According to public reporting, the White House recently proposed a Compact for Academic Excellence in Education (“Compact”) to nine universities, promising a closer relationship with the White House, preferential access to...more
The Trump Administration announced its intent to overhaul federal grantmaking and grant administration in an August 7 Executive Order titled Improving Oversight of Federal Grantmaking....more
8/13/2025
/ Colleges ,
Contract Termination ,
Contract Terms ,
Diversity and Inclusion Standards (D&I) ,
Executive Orders ,
Federal Grants ,
Funding Opportunities ,
New Guidance ,
OMB ,
Regulatory Oversight ,
Trump Administration ,
Universities
On July 29, 2025, the Department of Justice (“DOJ”) released a Memorandum emphasizing the Trump administration’s focus on eliminating diversity, equity, and inclusion (“DEI”) and DEI-like programs....more
The Department of Justice and the Department of Health and Human Services announced the reinvigoration of a False Claims Act (“FCA”) Working Group, a joint effort between the two agencies. ...more
7/10/2025
/ Centers for Medicare & Medicaid Services (CMS) ,
Department of Health and Human Services (HHS) ,
Department of Justice (DOJ) ,
Drug Pricing ,
Enforcement Priorities ,
False Claims Act (FCA) ,
Health Care Providers ,
Healthcare Fraud ,
Medicaid ,
Medical Devices ,
Medicare ,
Medicare Advantage ,
Pharmaceutical Industry ,
Popular ,
Prescription Drugs ,
Working Groups
The United States Supreme Court issued a decision that curtailed the practice of “universal” or “nationwide” injunctions and may have a significant impact for individuals and organizations that seek redress from the courts,...more
6/30/2025
/ Administrative Procedure Act ,
Article III ,
Executive Orders ,
Injunctions ,
Injunctive Relief ,
Judicial Authority ,
Litigation Strategies ,
Preliminary Injunctions ,
SCOTUS ,
Statutory Interpretation ,
Trump Administration ,
Trump v CASA