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Civil Monetary Penalty Federal Contractors

DirectEmployers Association

OFCCP Week In Review: January 2024 #3

Wednesday, January 10, 2024: US DOL‘s WHD Published Its “Employee or Independent Contractor” Classification Final Rule - The U.S. Department of Labor’s (“DOL”) Wage and Hour Division (“WHD”) published its much anticipated...more

Pillsbury Winthrop Shaw Pittman LLP

Proposed Rules Overhaul Cybersecurity Requirements for Government Contractors

The Federal Acquisition Regulation (FAR) Council has proposed two new cybersecurity rules that would impose significant obligations and risks for federal government contractors. The proposed rules impose substantial cyber...more

Womble Bond Dickinson

Handle with Care: FCPA Travel & Hospitality Expenses

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Two recent Foreign Corrupt Practices Act (FCPA) actions – a Department of Justice (DOJ) Opinion letter and an SEC settlement – underscore key diligence questions that legal and compliance departments should address when...more

DirectEmployers Association

OFCCP Week In Review - March 2023 #4

...DHI Group Inc. (“DHI”) is a job-search website operator posting corporate job vacancies for technology professionals on its Dice.com website. DHI has now agreed to settle numerous U.S. Equal Employment Opportunity...more

Bass, Berry & Sims PLC

False Claims Act Fundamentals: Reverse False Claims

Previous False Claims Act (FCA) Fundamentals posts have examined how violations of certain federal laws can potentially expose entities to FCA liability when they receive money from the government. This post focuses on how...more

DirectEmployers Association

OFCCP Week In Review - January 2023 #3

New Congressional Research Service Reports Explain “Holman Rule” By a 220 – 213 essentially party-line vote, the U.S. House of Representatives passed its procedural rules package (H.Res.5) that includes the “Holman Rule.”...more

Dorsey & Whitney LLP

Latest PPP Fraud Settlement Showcases Civil and Criminal Penalties for Knowingly Submitting False Claims

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The Department of Justice (“DOJ”) continues racking up more settlement agreements under the False Claims Act, 31 U.S.C. § 3729 et seq (“FCA”) with companies and individuals alleged to have improperly used funds received...more

Baker Donelson

Cybersecurity: A Whistleblower's Paradise

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Cyber whistleblowing is the newest and hottest area of exposure for organizations. All government contractors and grant recipients must develop an understanding of the use of the False Claims Act (FCA) to address...more

DirectEmployers Association

OFCCP Week In Review: February 2022 #4

The DE OFCCP Week in Review (WIR) is a simple, fast and direct summary of relevant happenings in the OFCCP regulatory environment, authored by experts John C. Fox, Candee Chambers and Jennifer Polcer. In today’s edition, they...more

DirectEmployers Association

OFCCP Week In Review: January 2022 #3

The DE OFCCP Week in Review (WIR) is a simple, fast and direct summary of relevant happenings in the OFCCP regulatory environment, authored by experts John C. Fox, Candee Chambers and Jennifer Polcer. In today’s edition, they...more

ArentFox Schiff

DOJ's New Civil Cyber-Fraud Initiative and How a Pending Case Could Test Its Efficacy

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The Department of Justice recently announced a new initiative that aims to hold government contractors accountable when they fail to meet required cybersecurity standards. In announcing the “Civil Cyber-Fraud Initiative” in...more

DirectEmployers Association

OFCCP Week In Review: September 2021 #4

The DE OFCCP Week in Review (WIR) is a simple, fast and direct summary of relevant happenings in the OFCCP regulatory environment, authored by experts John C. Fox, Candee Chambers and Jennifer Polcer. In today’s edition, they...more

Vinson & Elkins LLP

Court Of Federal Claims Finds CDA Anti-Fraud Provision’s Statute Of Limitations Has A Hard Stop At 6

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For federal contractors, the Contract Disputes Act (“CDA”)1 can be a double-edged sword. While the CDA allows contractors to assert contractual claims against the Government, the CDA also contains an anti-fraud provision that...more

Cole Schotz

New Jersey Legalizes Recreational Cannabis And Enacts Employment Protections For Cannabis Users

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On February 22, 2021, Governor Phil Murphy signed the New Jersey Cannabis Regulatory, Enforcement Assistance, and Marketplace Modernization Act (“NJCREAMMA”), which legalizes the recreational use of cannabis for adults age 21...more

Health Care Compliance Association (HCCA)

Report on Medicare Compliance Volume 28, Number 36. News Briefs - October 2019

- Fresenius Medical Care North America Inc. has agreed to pay $5.2 million to settle allegations that it tested dialysis patients for Hepatitis B surface antigen more often than medically necessary and billed Medicare for the...more

ArentFox Schiff

Investigations Newsletter: Patient Recruiter Convicted in $1.3 Million Kickback Conspiracy Scheme

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Patient Recruiter Convicted in $1.3 Million Kickback Conspiracy Scheme - After a six-day trial, a federal jury in Detroit found a patient recruiter guilty of one count of conspiracy to pay and receive health care...more

ArentFox Schiff

Investigations Newsletter: Hospital to Pay Over $2 Million to Settle Alleged False Claims Act Violations

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DOJ News & Litigation Updates - ITT Cannon to Pay $11 Million to Settle False Claims Allegations - ITT Cannon (ITT), a division of ITT Inc., has agreed to pay $11 million to settle whistleblower claims that it supplied...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Alleged Environmental Violation/False Claims Act: U.S. District Court Considers Application of Implied False Certification Theory

A United States District Court (Eastern District-Pennsylvania) (“Court”) addressed a qui tam action filed by Gary Cressman (“Cressman”) under the federal False Claims Act (“FCA”) in connection with an alleged environmental...more

Bass, Berry & Sims PLC

Small Business Fraud Leads to Large Monetary Liability in Recent Cases

Two Washington, D.C. area government contractors have agreed to pay the government for their respective roles in defrauding the U.S. Small Business Administration (SBA) in schemes to fraudulently obtain government contracts...more

PilieroMazza PLLC

Weekly Update Newsletter - February 2018 #2

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GOVERNMENT CONTRACTS - Pentagon Warns CEOs: Protect Your Data or Lose Our Contracts - According to an article from Govexec.com, the Pentagon has issued a warning to defense-industry contractors, insinuating that they...more

PilieroMazza PLLC

Weekly Update Newsletter - January 2018 #3

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GOVERNMENT CONTRACTS - General Services Administration Acquisition Regulation (GSAR); Federal Supply Schedule, Order-Level Materials - The General Services Administration (GSA) is amending the General Services...more

Dorsey & Whitney LLP

Early Resolution of FCA Civil Damages Under the Eighth Amendment’s Excessive Fines Clause? A Pending Case in Washington May...

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The False Claims Act authorizes civil penalties between $10,781 to $21,563 per false claim, as well as three times the amount of damages which the government sustains (i.e. treble damages). The Eighth Amendment provides that...more

Bass, Berry & Sims PLC

FCA Deeper Dive: Developments Regarding Penalties and Damages

The FCA continues to be the federal government’s primary civil enforcement tool for investigating allegations that healthcare providers or government contractors defrauded the federal government. In the coming weeks, we...more

Hogan Lovells

Top False Claims Act developments In 2017 for ADG companies

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The False Claims Act, 31 U.S.C. §§ 3729-3733, continues to pose unique liability risk for aerospace, defense, and government services (ADG) companies that directly or indirectly conduct business with the U.S. Government. In...more

Bradley Arant Boult Cummings LLP

False Claims Act: 2016 Year in Review

We are pleased to present Bradley’s annual review of significant False Claims Act (FCA) cases, developments, and trends. From a relatively short article several years ago, the Review has grown to a significant publication...more

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