Articles and Blogs

On April 15, 2024, the Criminal Division of the Department of Justice (“DOJ”) issued a new pilot program to incentivize individuals to come forward with voluntary disclosures (the “Program”). Under this Program, individuals with criminal exposure who come forward and report misconduct that was otherwise unknown to the DOJ may be eligible to receive... READ MORE

In an effort to not only establish a uniform standard for how U.S. Attorney Offices (“USAOs”) assess and credit voluntary self-disclosures but to also incentivize early and voluntary self-disclosure of corporate criminal misconduct, the Department of Justice (“DOJ”) has implemented a new Voluntary Self-Disclosure (“VSD”) Policy to be used by USAOs nationwide (the “Policy”).... READ MORE

On July 11, 2019, the Office of Inspector General (“OIG”) for the U.S. Department of Health and Human Services (“HHS”) released the new Grant Self-Disclosure Program Guidance (“Grant Guidance”) for HHS grant recipients and subrecipients. Through the Grant Guidance, OIG provides new self-reporting options for HHS grant recipients and subrecipients who determine that they... READ MORE

The Centers for Medicare & Medicaid Services (“CMS”) recently updated its Voluntary Self-Referral Disclosure Protocol (“SRDP”) when it posted a new form to be used as part of the SRDP process (“SRDP Form”). According to CMS, the SRDP Form is an attempt to “streamline and simplify” the SRDP process. CMS originally proposed the new SRDP... READ MORE

Written by David B. Honig and Ritu Kaur Cooper. On February 3, 2015, the Fourth Circuit Court of Appeals ruled that disclosures to the public officials responsible for managing the subject of a False Claims Act lawsuit did not qualify as “public disclosures” for the purpose of the FCA’s public disclosure bar. US ex rel. Wilson v.... READ MORE