Numerous commentaries predict an outbreak of False Claims Act investigations and cases related to allegations of misuse, fraud, waste, and abuse of funding provided under the CARES Act. With the tremendous sums of money at issue and the likely difficult economic conditions faced by many recipients, there are countless opportunities and temptations to misuse these funds. Like all federal monies, CARES Act money comes with strings attached. Under the current crisis conditions, with remote workers and reduced staffing, it is also likely that recipients may not be as vigilant in their compliance efforts as they would be under “normal” circumstances. Under these conditions, mistakes and oversights are more likely.
