As if more evidence were needed, a recent Department of Justice (DOJ) indictment provides another reminder of the importance of an effective compliance program—and the potential costs to contractors if their program doesn’t prevent fraudulent actions by individual employees. Last week, the DOJ announced it has entered into a non-prosecution agreement (NPA) with Alutiiq InternationalRead More
If you were somehow still wondering whether small businesses really need to be concerned about the affiliation rules in the Small Business Administration (SBA) regulations, the answer is a resounding “Yes.” Furthermore, running afoul of those rules can easily lead to liability under the False Claims Act (FCA), as most recently demonstrated by an OklahomaRead More
I. Introduction The Paycheck Protection Program (PPP) was enacted as part of the Coronavirus Aid, Relief, and Economic Security (CARES) Act on March 27, 2020. Unfortunately, the path to providing PPP loan relief has not been smooth. Instead, it has been paved with uncertainty. While the CARES Act laid out specific requirements for PPP eligibility and relief, theRead More
On Monday, April 6, the U.S. Department of Justice (DOJ) announced that MiMedx Group Inc. (MiMedx or the company), an advanced wound care and biologics company, agreed to pay $6.5 million to resolve allegations that it overcharged the U.S. Department of Veterans Affairs (VA) by knowingly submitting false statements and disclosures regarding inflated prices forRead More
The U.S. Department of Justice (DOJ) announced it has taken its first action in federal court to combat fraud related to the coronavirus (COVID-19) pandemic. The heightened fraud enforcement establishes a new precedent for government contractors, in particular, to take extra steps to ensure robust compliance measures are in place, to review supply chain agreements,Read More