On May 29, 2009, President Obama signed into law the Fraud Enforcement and Recovery Act of 2009 ("FERA").[1] FERA implements a number of sweeping changes to the False Claims Act ("FCA"), including a provision that expands significantly the circumstances under which a contractor may be held liable under the so called "reverse false claims" theory.
Continue Reading Render Unto Caesar What Is Caesar’s … Or Else: The Expansion of False Claims Act Liability to the Retention of Overpayments