Congress has responded to the recent COVID-19 pandemic with relief spending at historic levels, including federal funds that are enabling agencies to award contracts and grants to assist in the immediate response and recovery effort. As the Venable Government Contracts Group recently discussed, with so much federal funding at stake, and being distributed in emergent, challenging, and ever-changing circumstances, improper claims for funds—both intentional and unintentional—are inevitable. In that article, we outlined five important steps to avoiding False Claims Act (FCA) liability. Here, we discuss two recent court cases that highlight key ways contractors should act now to prevent and prepare for possible whistleblower complaints in the months to come.
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Contractors Performing COVID-19 Relief Work Should Start Preparing for Whistleblower Complaints Now
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