As federal contractors continue to navigate the post-pandemic compliance landscape, a recurring issue has emerged in government audits and incurred cost reviews: whether and how contractors must credit the government for...more
6/12/2025
/ Audits ,
Best Practices ,
CARES Act ,
Contract Disputes ,
Coronavirus/COVID-19 ,
DCAA ,
Defense Contracts ,
False Claims Act (FCA) ,
Federal Acquisition Regulations (FAR) ,
Federal Contractors ,
Loan Forgiveness ,
Loans ,
Paycheck Protection Program (PPP) ,
Small Business
The Department of Justice (DOJ) recently announced that it obtained more than $2.68 billion in False Claims Act (FCA) settlements and judgments in the fiscal year ending September 23, 2023. DOJ reports that “matters that...more
The year 2021 marks the 10th anniversary of the Bradley False Claims Act Year in Review. In that decade, much has remained the same in FCA enforcement. To start with the obvious: It continues to result in billions of dollars...more
2/3/2022
/ Alternate Remedy ,
Anti-Kickback Statute ,
CARES Act ,
Causation ,
Class Action ,
Cybersecurity ,
Damages ,
Department of Justice (DOJ) ,
Dismissals ,
Enforcement Actions ,
False Claims Act (FCA) ,
Fraud ,
Government Investigations ,
Healthcare ,
Local Coverage Determination (LCD) ,
Materiality ,
Overpayment ,
Pleading Standards ,
Public Disclosure Bar ,
Request for Equitable Adjustment ,
Scienter ,
Settlement
As part of Bradley’s continued reporting on issues arising from the CARES Act and the Paycheck Protection Program (PPP) that uniquely impact government contractors, we summarize here a new Small Business Administration (SBA)...more
We previously reported on a series of issues arising from the CARES Act and Paycheck Protection Program (PPP) that uniquely impact government contractors. We have cautioned that government contractors should be mindful of the...more
The Government Accountability Office (GAO) recently issued a report to Congress titled COVID-19: Opportunities to Improve Federal Response and Recovery Efforts. Of note, the GAO reports that government-wide contract...more
Under the Paycheck Protection Program (PPP), borrowers can seek loan forgiveness of the full principal amount of loans as early as eight weeks after disbursement of the loan proceeds. On May 22, 2020, the U.S. Small Business...more
5/31/2020
/ Applications ,
Borrowers ,
CARES Act ,
Coronavirus/COVID-19 ,
FTEs ,
Interim Final Rules (IFR) ,
Lenders ,
Loan Forgiveness ,
Paycheck Protection Program (PPP) ,
Popular ,
Safe Harbors ,
SBA ,
Small Business
The Small Business Administration (SBA) updated its answers to frequently asked questions about the Paycheck Protection Program (PPP) on May 5, 2020, as follows:
Question: FAQ #31 reminded borrowers to review carefully the...more
On April 30, the Federal Reserve announced substantial changes to the initial terms of its Main Street Lending Program originally released on April 9, 2020:
After receiving over 2,200 comment letters and consulting with...more
5/5/2020
/ Borrowers ,
CARES Act ,
Commercially Reasonable Efforts ,
Coronavirus/COVID-19 ,
Federal Loans ,
Federal Reserve ,
Financial Stimulus ,
Lenders ,
Main Street Lending Programs ,
Main Street New Loan Facility ,
SBA ,
SPVs ,
Term Sheets ,
U.S. Treasury
We recently reported on a series of Paycheck Protection Program (PPP) issues that uniquely impact government contractors. As we noted, particularly concerning for federal contractors is that agencies may seek credits or...more
In the last few days, the Small Business Administration (SBA) provided additional answers to frequently asked Paycheck Protection Program (PPP) questions and published yet another interim final rule on the administration of...more
On April 24, 2020, the Paycheck Protection Program and Health Care Enhancement Act was signed into law and provided an additional $310 billion for the Paycheck Protection Program (PPP). The Small Business Administration (SBA)...more
On April 23, 2020, the Small Business Administration (SBA) updated its Answers to Frequently Asked Questions about the Paycheck Protection Program (PPP). Among the most noteworthy updates is the following answer provided by...more
Many federal contractors have already taken advantage of the Paycheck Protection Program (PPP), which was established by the CARES Act to help small businesses and other eligible applicants survive the economic impact of the...more
On April 14, 2020, the Small Business Administration (SBA) posted an additional Interim Final Rule for the Paycheck Protection Program (PPP). This new Interim Final Rule functions as a supplement to the first PPP Interim...more
On April 9, 2020, the Federal Reserve announced a new “Main Street” Lending Program that will facilitate lending by banks and other financial institutions to mid-size businesses. The program is comprised of two separate...more
On April 7, 2020, the Small Business Administration (SBA) issued additional guidance on the Paycheck Protection Program (PPP) in the form of answers to frequently asked questions about the PPP. According to the new guidance,...more
In the wake of the COVID-19 pandemic response, government contractors have experienced varying degrees of work disruption. As highlighted recently by the Office of Management and Budget (OMB), “Federal contractors play a...more
As we discussed in a previous article, the Coronavirus Aid, Relief, and Economic Security Act, known as the “CARES Act,” provides much-needed relief to “small” businesses in several areas, including by appropriating...more
In response to the COVID-19 pandemic, Congress recently passed, and President Trump signed, the Coronavirus Aid, Relief, and Economic Security Act, known as the CARES Act. Described in the media as the “largest emergency aid...more