Tag Archives: Contractor

What Exactly Is DCAA Thinking?

Recently, contractors have begun receiving formal requests for information from the Defense Contract Audit Agency (“DCAA”). The purported purpose of these requests is to “[o]btain an understanding of the management control environment” of major government contractors. In pursuit of this goal, DCAA has crafted a letter that demands, among other things, the following: A list … Continue Reading

Render Unto Caesar What Is Caesar’s … Or Else: The Expansion of False Claims Act Liability to the Retention of Overpayments

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
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