News & Analysis as of

Paycheck Protection Program (PPP) Audits

J.S. Held

Current Enforcement Efforts in the Battle Against COVID-19 Loan Program Fraud

J.S. Held on

The COVID-19 pandemic caused unprecedented impacts around the world including stay-at-home orders, curfews, quarantines, and economic uncertainty. Businesses across the United States were forced to close their doors, limit...more

Husch Blackwell LLP

BOLO: Cannabis PPP Loan Audits

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In April, I wrote about the Docklight case in Washington State. That case involved a qui tam action pursuant to the False Claims Act in which Docklight, a cannabis ancillary company, settled with the Department of Justice for...more

Benesch

Engaging in Activities that Violate Federal Law? DOJ Scrutiny of PPP Loan Recipients Turns to Ancillary Companies Supporting the...

Benesch on

Since its inception, the cannabis industry has always existed alongside significant regulatory and compliance challenges. These largely stem from the fact that the manufacture, distribution and possession of marijuana remains...more

Husch Blackwell LLP

PPP Loan Audits Could Affect Millions of Borrowers

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In March 2020 during the height of the COVID-19 pandemic, the Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law establishing, among other things, the Payment Protection Program (PPP) administered...more

McDermott Will & Emery

The PPP Turns Four: Lessons Learned and What Lies Ahead

McDermott Will & Emery on

Four years ago this month, lenders began dispersing Paycheck Protection Program (PPP) loans to small businesses in what would become the largest Small Business Administration (SBA) lending program in history. The SBA approved...more

Fox Rothschild LLP

ERC Voluntary Disclosure Deadline Rapidly Approaching on March 22

Fox Rothschild LLP on

The March 22 deadline for applying to the IRS Voluntary Disclosure Program (VDP) to repay improperly claimed Employee Retention Credits (ERC) at a discount is just around the corner. The VDP requires businesses to repay only...more

Mintz - Health Care Viewpoints

EnforceMintz — The Pandemic May Be Ending, But Fraud Prosecutions Will Keep Coming

The “epidemic” of COVID-19 related fraud continued unabated in 2022, and we expect to see the same in 2023. The Department of Justice (DOJ) appears poised to continue to aggressively investigate and prosecute COVID-19-related...more

Venable LLP

Navigating PPP Loan Forgiveness Audits

Venable LLP on

The Small Business Administration (SBA) is auditing Paycheck Protection Program (PPP) loan forgiveness applications for both First Draw and Second Draw PPP loans, including for nonprofit organizations that received loans. As...more

PilieroMazza PLLC

PPP Loan Fall-Out: Expect More Audits and Investigations

PilieroMazza PLLC on

Unfortunately, the PPP Loan fall-out is far from over.  As we noted in the last blog on PPP issues, we are seeing a number of PPP Forgiveness denials for a number of different reasons, and, along with that, we are seeing the...more

Cozen O'Connor

In extremis — PPP Money Is Not “Free” So Applicants & Recipients Need to Beware

Cozen O'Connor on

As most of the population is aware, to try and preserve the economy and businesses viable during the COVID-19 pandemic, congress passed the CARES Act. That bill included the Payroll Protection Program (PPP), in which small...more

Morrison & Foerster LLP

PPP Loans: Overview of Prior Guidance

The Paycheck Protection Program (“PPP”) began with rushed legislation and a race for financial support in the middle of a pandemic. This race was hardly a straight line as the Small Business Administration (“SBA”) and the...more

Bowditch & Dewey

Five Things to Know About PPP Loan Audits

Bowditch & Dewey on

The Paycheck Protection Program was one of the more innovative and written-about of the CARES Act’s fiscal stimulus packages. The U.S. Treasury and Small Business Administration (SBA) leveraged the private banking sector to...more

Blank Rome LLP

Paycheck Protection Program Audits Are Upon Us—Borrowers Prepare!

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In our last post on this topic, we touched on how the acceptance, use, and forgiveness of Paycheck Protection Program (“PPP”) loans can be viewed in the context of a Defense Contract Audit Agency (“DCAA”) audit. This post...more

Vinson & Elkins LLP

A Second Wave Of COVID-19 Fraud Enforcement: An Emerging Risk For Businesses

Vinson & Elkins LLP on

On March 26, 2021, the Department of Justice (“DOJ”) issued a press release trumpeting the agency’s “historic level of enforcement action” in response to COVID-19 related fraud. Roughly one year after Congress passed the $2.2...more

McDermott Will & Emery

[Webinar] PPP - One Year Later - April 8th, 2:00 pm EST

It has now been one full year since the Small Business Administration launched its Paycheck Protection Program (PPP). As we take a look back and begin to prepare for the next steps that organizations must take now to insulate...more

Chambliss, Bahner & Stophel, P.C.

On the Horizon for 2021 — Paycheck Protection Program and Provider Relief Fund Reporting Requirements and Audits

If your radiology practice received payments from the U.S. Department of Health and Human Services (HHS) Provider Relief Fund (PRF) or a loan under the Paycheck Protection Program (PPP) in 2020, you are likely aware of the...more

K&L Gates LLP

HUB Talks: Voluntary Disclosure: Deep Dive - They Still Know What You Did Last Summer—Phase 2 of the U.S. Government's Response to...

K&L Gates LLP on

In this second episode of our series on the government's response to the Paycheck Protection Program, white collar practitioners Chris Nasson, David Rybicki, Neil Smith, and Hayley Trahan-Liptak discuss the second phase of...more

Blank Rome LLP

COVID Audits and Investigations: The Enforcers

Blank Rome LLP on

This is the first in a series of blog posts concerning the audits and investigations related to the contracts and grants awarded, and relief funds provided, in response to the COVID-19 pandemic. As of February 2021, pursuant...more

Burr & Forman

Are You Ready for Your PPP Loan Audit?

Burr & Forman on

PPP loans received by individuals and businesses under the CARES Act will be audited (“reviewed”) by the SBA.  The new Economic Aid Act also requires the SBA to submit a forgiveness audit plan within 45 days after enactment...more

Chambliss, Bahner & Stophel, P.C.

What You Need to Know About Latest Paycheck Protection Program Regulations and Second Draw Loans

As we have reported, the stimulus bill passed by Congress and signed by President Trump late last year enacted major changes to the popular Paycheck Protection Program (PPP). And this week, consistent with that law’s 10-day...more

King & Spalding

Provider Relief Fund Updates: COVID-19 Relief Package and OMB 2020 Compliance Supplement Addendum

King & Spalding on

Last week, as reported in the December 21 Health Headlines, bipartisan congressional leaders announced they had reached an agreement on a COVID-19 relief package––which would be combined into one end of year legislative...more

Chambliss, Bahner & Stophel, P.C.

Key Guidance on SBA's Loan Necessity Questionnaire for Paycheck Protection Program Loans

The U.S. Small Business Administration (SBA) issued guidance on the recently issued “Loan Necessity Questionnaire” (SBA Form 3509/3510). Lenders must require Paycheck Protection Program (PPP) borrowers to complete the...more

Harris Beach Murtha PLLC

PPP Loan Forgiveness Applications and Increase in Federal Investigations Pose Risks for Small Businesses

A significant part of the March 2020 CARES Act, the federal government’s Paycheck Protection Program (PPP) provided a lifeline for hundreds of thousands of small businesses across the nation, helping struggling owners pay...more

Fox Rothschild LLP

SBA Announces New Paycheck Protection Program Loan Necessity Questionnaire

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On October 26, the Small Business Administration (SBA) published a notice in the Federal Register seeking approval from the Office of Management and Budget to release two new forms to be sent to borrowers under the Paycheck...more

Parker Poe Adams & Bernstein LLP

SBA Reveals Questionnaires Aimed at Auditing Necessity of Large Paycheck Protection Program Loans

In a series of FAQs issued last spring, the Small Business Administration (SBA) made clear that it would review the certification made by Paycheck Protection Program (PPP) borrowers of $2 million or more that “[c]urrent...more

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