News & Analysis as of

Compliance False Claims Act (FCA)

Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations. ... more +
Compliance programs typically refer to formalized institutional procedures within corporations and organizations to detect, prevent and respond to indvidual and widespread instances of regulatory violations.  In response to many corporate scandals evidencing rampant unethical business practices, many nations, including the United States, began passing strict regulatory frameworks aimed at curbing these abuses. Notable pieces of legislation in this area include the U.S. Foreign Corrupt Practices Act (FCPA), Sarbanes-Oxley (SOX), and the U.K. Bribery Act, to name a few. The foregoing statutes and the severe penalties often associated with them form the basis of many modern institutional compliance programs. less -
Wiley Rein LLP

DOJ Launches Trade Fraud Task Force, Ramping Up Civil and Criminal Enforcement

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The U.S. Department of Justice (DOJ) recently announced the creation of an interagency Trade Fraud Task Force aimed at stepping up enforcement against tariff evasion and customs fraud. The Task Force will bring together the...more

DLA Piper

DOJ Officially Launches the Trade Fraud Task Force

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The US Department of Justice (DOJ), in coordination with the Department of Homeland Security (DHS), on August 29, 2025, launched a cross-agency Trade Fraud Task Force to bolster enforcement against tariff evasion, customs...more

Holland & Hart LLP

Correcting Stark Violations: 90-Day Grace Period

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Physicians and entities to which physicians refer may violate the Ethics in Patient Referrals Act (“Stark”) by mistakenly overpaying or underpaying amounts due under a compensation arrangement. For example, a hospital may...more

Oberheiden P.C.

Pharmacy Claim Reversals: Mitigating Risk Before, During, and After an Investigation

Oberheiden P.C. on

Pharmacy claim reversals can be costly. Not only can they have an immediate impact on pharmacies’ cash flow; but, in many cases, they can lead to additional consequences as well. Pharmacies accused of improperly billing...more

StoneTurn

Tariffs Meet COSO: A Two-Way Street to Risk & Opportunity Management

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In today’s global trade environment, tariffs have become a company-wide concern—impacting legal, compliance, finance, and operations alike. This article introduces how the COSO Internal Control Framework can serve as a...more

Oberheiden P.C.

Department of Defense and Defense Logistics Agency Debarment and Suspension: 7 Key Defense Strategies

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Debarment and suspension present significant financial and legal risks for defense contractors. As a result, when facing debarment or suspension by the U.S. Department of Defense (DOD) or the Defense Logistics Agency (DLA),...more

Paul Hastings LLP

CMS Proposes Major ASP Reporting Overhaul — Implications for Fair Market Value and Bona Fide Service Fees

Paul Hastings LLP on

The Centers for Medicare & Medicaid Services (CMS) recently published its Proposed 2026 Physician Fee Schedule Rule (Proposed Rule), with extensive implications for drug pricing, Average Sales Price (ASP) calculations, and...more

Husch Blackwell LLP

The Risks of Trade-Related FCA Enforcement

Husch Blackwell LLP on

In March 2025, in a similar blog post to this one, Nithya Nagarajan and Robert Romashko forecasted that False Claims Act (“FCA”) enforcement would increase under the current tariff-focused trade policy regime. Sure enough,...more

McCarter & English Blog: Government Contracts...

New “Unlawful Discrimination” Guidance from DOJ Underscores Risks to Federal Grant Recipients

Earlier this year, we addressed a growing sense of confusion and unease among federal contractors relating to shifting diversity, equity, and inclusion (DEI) standards. Specifically, awardees had to take stock of the...more

Skadden, Arps, Slate, Meagher & Flom LLP

DOJ Settlement With Medical Technology Company Signals Expanding Cybersecurity FCA Risk for Life Sciences Companies

- What is new: DOJ announced a $9.8 million FCA settlement with Illumina Inc. to resolve claims arising out of alleged cybersecurity deficiencies in DNA sequencing systems Illumina sold to government agencies. - Why it...more

Thomas Fox - Compliance Evangelist

Great Women in Compliance: LATAM Compliance Update with Alejandra Montenegro Almonte

In this episode of Great Women in Compliance, Lisa speaks with Alejandra Montenegro Almonte, a member at Miller Chevalier. Alejandra is the Chair of their International Practice and Practice Co-Lead, Workplace Culture. They...more

Mintz - Health Care Viewpoints

“False” Sense of Security: DOJ Announces False Claims Act Settlements Related to Failure to Comply with Cybersecurity Requirements

On July 31, 2025, the United States Department of Justice (DOJ) announced a pair of settlements with companies accused of having violated the False Claims Act (FCA) by falsely representing their compliance with certain...more

White & Case LLP

DOJ and HHS Relaunch False Claims Act Working Group, Sharpen Healthcare Enforcement Priorities

White & Case LLP on

On July 2, 2025, the U.S. Department of Justice (DOJ) and the Department of Health and Human Services (HHS) jointly announced the reestablishment of the DOJ-HHS False Claims Act (FCA) Working Group. While the two agencies...more

Husch Blackwell LLP

OIG Announces 2025 Work Plan Review: What Clinical Laboratories Need to Know About Medicare Payments for Diagnostic Lab Tests

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In June 2025, the U.S. Department of Health and Human Services Office of Inspector General (OIG) announced a new item in its Work Plan: “Medicare Payments for Clinical Diagnostic Laboratory Tests in 2024.” This annual review,...more

Mogin Law LLP

Antitrust Enforcers Renew Call for Whistleblowers

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The Justice Department’s Antitrust Division has announced a new Whistleblower Rewards Program, offering incentives to individuals to report “antitrust crimes and related offenses that harm consumers, taxpayers, and free...more

Clark Hill PLC

Key lessons on the False Claims Act for government contractors after Raytheon’s $8.4 million settlement

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Government contractors should be on high alert following the recent announcement that Raytheon Company, its parent RTX Corporation, and Nightwing Group, LLC, have agreed to pay $8.4 million to resolve allegations of violating...more

ArentFox Schiff

As the (Customs and Trade) World Turns: July 2025

ArentFox Schiff on

Welcome to the July 2025 issue of “As the (Customs and Trade) World Turns,” our monthly newsletter where we compile essential updates from the customs and trade world over the past month. We bring you the most recent and...more

Buchalter

Blame It on the Bot: Health Care Fraud and Compliance in theAge of AI

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A large health system implements an Artificial Intelligence (AI)-powered clinical decision support tool that promises to ensure “complete and accurate” diagnosis documentation. Within six months, the system’s Medicare...more

Womble Bond Dickinson

[Webinar] Compliance Priorities for In-House Counsel: Responding to Latest DOJ Priorities & Guidance - August 5th, 3:00 pm - 4:00...

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Join us for an informative webinar providing the latest updates on key compliance issues under the current administration. Our panel will address recent developments in tariffs, the FCPA, False Claims Act, and sanctions....more

Arnall Golden Gregory LLP

When DEI Meets the FCA: What Employers Need to Know About the DOJ’s Civil Rights Fraud Initiative

In this episode, AGG Employment partner and co-chair, Ashley Kelly, speaks with leaders of the firm's new Civil Rights & False Claims Act Risk & Response Team, Gabe Scannapieco and Sara Lord, about the DOJ’s recent move to...more

ArentFox Schiff

Investigation Newsletter: DOJ and HHS Emphasize Continued, Robust, and Coordinated Health Care Enforcement with Revival of False...

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The government has announced a renewed and expanded focus on False Claims Act (FCA) enforcement, doubling down on traditional health care priorities like kickbacks and drug pricing while signaling increased scrutiny of...more

Bradley Arant Boult Cummings LLP

Navigating Federal Solicitations with Artificial Intelligence

As the federal government continues to modernize procurement processes and embrace emerging technologies, contractors are increasingly turning to artificial intelligence (AI) tools to streamline their responses to...more

Dentons

Ep. 66 – Mid-year Compliance Check-in: Three New Enforcement Priorities to Add to Your 2025 Work Plan

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As we hit the halfway point of 2025, now is the perfect time to revisit your compliance work plan. While it’s always good practice to assess whether your organization is meeting its compliance goals, this year presents a...more

Jackson Lewis P.C.

Enhanced AFCA Empowers Agency Fraud-Fighting, Creates Compliance Concerns for Federal Contractors and Others

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Significant revisions to the Program Fraud Civil Remedies Act of 1986 (PFCRA), now called the Administrative False Claims Act (AFCA), bolster federal agencies’ ability to address alleged fraud by expanding their authority to...more

ArentFox Schiff

FCA Enforcement & Compliance Digest — Summer 2025 False Claims Act Newsletter

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Welcome to the Summer 2025 issue of “FCA Enforcement & Compliance Digest,” our quarterly newsletter in which we compile essential updates on False Claims Act (FCA) enforcement trends, litigation, agency guidance, and...more

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