News & Analysis as of

False Claims Act (FCA) Colleges Title IV

Vorys, Sater, Seymour and Pease LLP

False Claims Act Reimagined: DOJ Pursues Civil Rights Fraud in Higher Education and Government Contracts

On May 19, 2025, the U.S. Department of Justice (DOJ) unveiled the Civil Rights Fraud Initiative, a new enforcement strategy aimed at leveraging the False Claims Act to hold colleges, universities, government contractors, and...more

Husch Blackwell LLP

DOJ’s Plan to Use the False Claims Act to Address Civil Rights Fraud

Husch Blackwell LLP on

According to a memorandum issued on May 19, 2025, the Department of Justice (“DOJ”) will use the False Claims Act as a tool to enforce federal civil rights laws. The new policy memo has serious potential implications for...more

Troutman Pepper Locke

The False Claims Act Enters the School Zone

Troutman Pepper Locke on

On May 19, 2025, the U.S. Department of Justice (DOJ) announced the launch of a Civil Rights Fraud Initiative, which will use the False Claims Act (FCA) as a basis for investigating the diversity, equity, and inclusion (DEI)...more

Fisher Phillips

New Civil Rights Fraud Initiative Puts More Pressure on Higher Ed and K-12 Schools Receiving Federal Funding: What to Do in...

Fisher Phillips on

Federal officials on Monday launched a new Civil Rights Fraud Initiative aimed at schools receiving federal funding, the next step in the Trump administration’s aggressive enforcement posture against transgender rights, DEI,...more

Snell & Wilmer

Scope of FCA Liability Illustrated In Recent Actions Against Higher Education Institutions

Snell & Wilmer on

In the past five years, the Federal Government and “Qui Tam” Realtors have ramped up False Claims Act (“FCA”) actions against higher education institutions. These actions highlight the scope and breadth of potential FCA...more

Bass, Berry & Sims PLC

Ninth Circuit Holds that Escobar Set Forth Exclusive Conditions for Implied Certification Liability

Bass, Berry & Sims PLC on

On August 24, 2018, the Ninth Circuit addressed the Supreme Court’s decision in Universal Health Services, Inc. v. U.S. ex rel. Escobar, holding that Escobar sets forth the exclusive test for establishing FCA liability under...more

McCarter & English, LLP

Universities Are Prime Targets for False Claims Act Liability

McCarter & English, LLP on

Colleges and universities receive billions of dollars in federal funds, whether through research grants or student financial aid, or even by billing Medicare or Medicaid for services rendered at academic medical centers. As a...more

Bass, Berry & Sims PLC

Seventh Circuit Revisits Sanford-Brown, Rejects Implied Certification Claim

Bass, Berry & Sims PLC on

In one of the few cases to apply the Supreme Court’s recent decision in Universal Health Services v. Escobar, the Seventh Circuit recently revisited and affirmed its prior rejection of an implied certification claim under the...more

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