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Federal Contractors and Subcontractors May Want to Double-Check the Liability Caps in Their Agreements After This Court Decision

When two companies negotiate a subcontract in support of a federal government prime contract ("federal subcontract"), they may include provisions capping their liability to each other at specific amounts. In structuring such...more

OIG Enhanced Review: OIG to Investigate the Life Cycle of Managed Care Contracts

In August 2023, the Office of Inspector General for the Department of Health and Human Services (OIG) announced a new strategic plan to investigate the life cycle of Medicare Advantage and Medicaid managed care contracts from...more

Is 2023 the "Year" of the False Claims Act? For the Courts, Congress, and Contractors, It Just Might Be

One hundred sixty years ago, Congress passed the False Claims Act (FCA) in response to widespread fraud committed against the United States government during the Civil War. Known as the "Lincoln Law," the FCA was originally...more

New Federal Law Aims to Identify and Prevent or Mitigate Organizational Conflicts of Interest in Federal Contracting

In the midst of the year-end legislative push, Congress last week passed S. 3905, the "Preventing Organizational Conflicts of Interest in Federal Acquisition Act." This "good government" law requires the Federal Acquisition...more

The Fourth Circuit enforces Safeco's rigorous, objective scienter requirement for Civil False Claims in Sheldon

On January 25, in United States ex rel. Sheldon v. Allergan, No. 20-2330 (4th Cir., Jan. 25, 2022), the United States Court of Appeals for the Fourth Circuit upheld a lower-court dismissal of a False Claims Act (FCA) case...more

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