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July 11, 2016, The Masters Conference
June 20, 2016, Inside Government Contracts
Last week, in Universal Health Services Inc. v. U.S. ex rel. Escobar, the Supreme Court unanimously affirmed the viability of the “implied false certification” theory of False Claims Act liability, at least in certain circumstances. Writing for a unanimous Court, Justice Thomas explained that a defendant can face FCA liability under an implied certification ...
May 21, 2016, Inside Government Contracts
This week, the Department of State (“State”), Verité, and other global NGOs, unveiled a sample human trafficking compliance plan and online resource to help contractors comply with the FAR’s anti-human trafficking rule (the “Rule”). As we have previously summarized, the Rule requires contractors to implement a compliance plan for contracts exceeding $500,000 ...
May 12, 2016, Inside Government Contracts
DoD, GSA, and NASA published a definition of “recruitment fees” for purposes of FAR 52.222-50 in today’s Federal Register. As we have previously discussed, the anti-trafficking requirements in FAR 52.222-50 were amended almost a year and a half ago to prohibit contractors from charging employees recruitment fees, without defining such fees. Subsequent efforts ...