As part of the Trump administration’s efforts to implement a broad range of executive orders targeting diversity programs and other policy priorities in federal grantmaking, OMB published a proposed rule on May 29, 2026, that would substantially revise the Uniform
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Canadian Steel Companies and Owner to Pay $19M to Settle False Claims Act Allegations Relating to Evaded Customs Duties
On May 20, 2026, the DOJ announced a settlement under the False Claims Act (FCA) with two Canada-based steel companies, Farjess Inc. and Royal Canadian Steel Inc., and their part-owner and president, Feroz Jessani. They agreed to pay $19 million
DOJ’s New West Coast Strike Force Puts Health Care Providers on Notice
The DOJ’s National Fraud Enforcement Division announced on April 30, 2026, the formation of the West Coast Health Care Fraud Strike Force, a multi-district enforcement initiative spanning Arizona, Nevada and the Northern District of California. Announced by Assistant Attorney General
HHS Inspector General Reminder: Kickback Liability Turns on Intent, Not Market Value or Stark Law Compliance
The U.S. Department of Health and Human Services Office of Inspector General (OIG) updated its FAQs on Fraud and Abuse Authorities to add a new answer on fair market value (FMV) in FAQ 17 and revise the answer on how
GSA AI Procurement Rules Would Introduce New Disclosure and Use-Rights Requirements for Federal Contractors
The General Services Administration Federal Acquisition Service has released draft contract terms and conditions related to AI-related procurements through a new proposed GSAR clause 552.239-7001, “Basic Safeguarding of Artificial Intelligence Systems” (February 2026), that would impose material new requirements on
Long Anticipated Medicare Advantage Compliance Guidance Heightens Investor and Provider Scrutiny
In February 2026, the Department of Health and Human Services, Office of Inspector General (HHS-OIG) issued its highly anticipated Industry Compliance Program Guidance for Medicare Advantage (MA ICPG), the first such compliance guidance for the MA industry in over 25
CMS Reaches $100 Million in Stark Self-Disclosure Settlements
The Centers for Medicare & Medicaid Services (CMS) recently released data on its 2025 settlements of voluntary self-disclosures related to past violations or potential violations of the physician self-referral law (the Stark Law). Generally, two notable items arise from our
Ninth Circuit Ruling in FCA Case Predicated on 340B Pricing Violations Has Significant Implications for Pharma Manufacturers
On March 17, 2026, the United States Court of Appeals for the Ninth Circuit issued a significant opinion in United States ex rel. Adventist Health System of West v. AbbVie Inc., [1] reversing the district court’s dismissal of a qui
New Executive Order Targets DEI Practices by Federal Contractors, Imposes Mandatory Contract Clause and FCA Liability
Continuing his administration’s efforts to eliminate diversity, equity and inclusion (DEI) activities, President Donald Trump signed an executive order, “Addressing DEI Discrimination by Federal Contractors,” on March 26, 2026, that directs all executive departments and agencies to include a new
New GSA Proposal Could Expose Federally Funded Institutions With Programs Perceived as DEI-Related
The General Services Administration has proposed requiring all federal funding recipients to certify that they do not maintain diversity, equity, inclusion and accessibility programs. Recipients also would also need to certify they are not knowingly hiring or recruiting undocumented staff.