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"The Federal False Claims Act - What Does It Mean for Nonproᯤt
Organizations?" Terry Elling & Dismas Locaria 1 Venable LLP
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1 "The Federal False Claims Act - What Does It Mean for Nonproᯤt Organizations?" Terry Elling & Dismas Locaria 1 Venable LLP THE CIVIL FALSE CLAIMS ACT: o The Civil False
Claims Act 2 ( FCA or Act ) imposes civil penalties and damages upon parties that submit false or fraudulent claims to the federal government. Speciᯤcally, the most commonly
invoked portion of the Act provides that: ELEMENTS: Any person who 1) knowingly presents, or causes to be presented, to an oᯤcer or employee of the United States
Government or a member of the Armed Forces of the United States a false or fraudulent claim for payment or approval is liable to the United States Government 3 o Most
courts read this language to require at least three essential elements: The presentation of a claim for payment to the U.S. Government; Claim The Act deᯤnes a claim as: [A]ny
request or demand, whether under a contract or otherwise, for money or property which is made to a contractor, grantee, or other recipient if the United States Government
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provides any portion of the money or property which is requested or demanded, or if the Government will reimburse such contractor, grantee, or other recipient for any portion
of the money or property which is requested or demanded. 4 Presentment presents, or causes to be presented : 1 Mr. Elling is a partner and Mr. Locaria is an associate in the
Government Contracts group in the Washington, D.C., oᯤce of Venable, LLP (www.venable.com) U.S.C et seq. 3 Id. at 3729(a)(1). 4 Id. at 3729(c). 1
2 The causes to be presented clause doe not require the person actually presenting the claim to know it is false. 5 A claim must be presented to an employee of the U.S.
Government, acting in his or her capacity as an employee of the U.S. Government. 6 Claims passed through prime contractors, grantees, etc. fall within the caused to be
presented clause to the U.S. Government. 7 In such instances the sub-contractor, grantee, etc. will be liable. 8 The claim must be false or fraudulent; and No statutory deᯤnition
for false or fraudulent. Largely deᯤned by judicial interpretation. The person knowingly presents a claim that is false or fraudulent. Knowingly - The Act deᯤnes knowing and
knowingly as: [A] person with respect to information has actual knowledge of the information; acts in deliberate ignorance of the truth or falsity of the information; or acts in
reckless disregard of the truth or falsity of the information, and no proof of speciᯤc intent to defraud is required. 9 5 See, e.g., U.S. v. Mackby, 261 F.3d 821, (9 th Cir. 2001). 6 See
U.S. ex rel. DRC, Inc. v. Custer Battles, LLC, No. 1:104CV199, 2005 U.S. Dist. LEXIS 13743, at * (E.D. Va. July 8, 2005). 7 See, e.g., U.S. ex rel. Totten v. Bombardier Corp., 286 F.3d
542, 547 (D.C. Cir. 2002). 8 See, e.g., U.S. v. Rachel, 289 F.Supp. 2d 688, (D. Md. 2003) U.S.C. 3729(b). 2
3 To meet the standard for reckless disregard, the government must only establish aggravated gross negligence, gross negligenceplus, or an extreme version of ordinary
negligence. 10 o Additional elements: Intent the knowing aspect of the FCA has lead to wide debate over a scienter (or intent) requirement. Courts vary on their interpretation,
but generally FCA liability requires a demonstration of more than mistake or negligence. 11 Materiality In 2008, the Supreme Court stated that the government must prove that
the defendant intended that the false record or statement be material to the Government s decision to pay or approve the false claim. 12 Damage Some courts require
damages for damages to be assessed. 13 PENALTIES/DAMAGES: o If an FCA violation occurs, the government can: Recover penalties up to three times the amount wrongfully
charged to the government (treble damages), and Fines between $5,500 and $11,000 per fraudulent claim. 14 The government may also be able to recover interest U.S. v. Krizek,
111 F.3d 934, (D.C. Cir. 1997). 11 See, e.g., U.S. ex rel. Oliver v. Parsons Co., 195 F.3d 457, (9 th Cir. 1999). 12 Allison Engine Co. v. U.S. ex rel. Sanders, No , 2008 WL (U.S. June 9,
2008). 13 See, e.g., United States v. Killough, 848 F.2d 1523, 1533 (11 th Cir. 1988) (allowing penalties but not damages to be assessed) U.S.C. 3729(a). 15 Although the FCA allows
the government to recover interest, most courts have found that treble damages are suᯤcient to make the government whole and, therefore, pre-judgment interest has not
generally been awarded. See, e.g., Foster Wheeler Corp., 447 F.2d 100 (2d Cir. 1971). 3
4 Penalties limited to two times amount wrongfully charged if full disclosure made to government within 30 days of knowledge of violation, full cooperation with investigation,
and no government investigation pending at time of disclosure. 16 DEFENSES: o Although the government s burden under the FCA is relatively low, the FCA is subject to several
defenses. These defenses include: Government Knowledge The government knowledge defense negates the falsity requirement, and the intent requirement that courts have
generally read into the FCA. 17 Courts have considered a host of factual issues in their analysis of the government knowledge defense, including a showing that the claimant did
not possess the requisite intent (scienter): The claimant s openness with the government about its operational problems; The on-site presence of government oᯤcials; The
availability of data demonstrating the operational problems; U.S.C. 3729(a)(2) 17 United States ex rel. Durcholz v. FKW Inc., 189 F.3d 542, 545 (7th Cir. 1999) ( If the government
knows and approves of the particulars of a claim for payment before the claim is presented, the presenter cannot be said to have knowingly presented a fraudulent or false
claim. In such a case, the government s knowledge eᯤectively negates the fraud or falsity required by the FCA. ); see also, Becker v. Westinghouse Savannah River Co., 305 F.3d
284, 289 (4th Cir. 2002) ( the government s knowledge of the facts underlying an allegedly false record or statement can negate the scienter required for an FCA violation ); see
also United States ex rel. Kreindler v. United Techs. Corp., 985 F.2d 1148, 1157 (2d. Cir. 1993); Shaw v. AAA Eng g & Drafting, Inc., 213 F.3d 519, 534 (10th Cir. 2000); United States
ex rel. Costner v. United States, 317 F.3d 883, 888 (8th Cir. 2003) (en banc). 4
5 The government s actual knowledge of the operational problems; and The government s actual knowledge of regulatory violations. 18 The government knowledge defense is
not an absolute defense. There are a number of factors that may negate this defense, such as: The government s knowledge was insuᯤcient to understand the falsity; 19 The
government s knowledge was incomplete; 20 The government was not informed of the falsity in a timely manner; 18 United States ex rel. Costner v. United States, 317 F.3d 883,
(8th Cir. 2003) (en banc). Similarly, courts have also found that government knowledge, coupled with an expressed desire by the government for the contractor to continue
performance, negates a FCA action against that contractor. See, e.g., Paradyne Corp. v. U.S. Dept. of Justice, 647 F.Supp. 1228, 1237 (D.D.C. 1986) (granting summary judgment in
favor of the contractor when a government agency has ᯤve times renewed a contract which it knew, or should have known, would be performed by a corporation which
allegedly used fraud to procure the contract in the ᯤrst instance. ). In addition, some courts view the government s knowledge and acquiesce to the alleged false conduct as not
actually false but rather conform[ing] to a modiᯤed agreement with the Government. United States ex rel. A+ Homecare, Inc. v. Medshares Management Group, Inc., 400 F.3d
428, 454 fn, 21 (6th Cir. 2005); see also United States ex rel. Windsor v. Dyncorp, Inc., 895 F.Supp. 844, 850 (E.D.Va. 1995) (granting summary judgment in favor of the defendant,
in part, because the government had full knowledge that over time, the contract became outdated and did not accurately correspond to existing conditions, and as a result it
was impossible for [the contractor] to provide some of the services required under the contract. ). Finally, government knowledge has been found by some courts to establish a
course of conduct that negated the allegations of false claims. See, e.g., United States v. Southland Management Corp., 326 F.3d 669, 675 (5th Cir. 2003) (en banc) ( When we
apply [the FCA] to the Contract [at issue] and the course of conduct between [the cognizant government agency] and the [claimant], we conclude upon this record that the
[claimants] were entitled to the... payments sought, and thus, they made no false claims. ). 19 See, e.g., United States ex rel. Durcholz v. FKW Inc., 189 F.3d 542, 545 (7th Cir.
1999) (stating that government s knowledge [is] not a bar to a FCA claim if the knowledge is incomplete or acquired too late in the process. ); see also United States ex rel. A+
Homecare, Inc. v. Medshares Management Group, Inc., 400 F.3d 428, 454 fn, 21 (6 th Cir. 2005) (ᯤnding the government knowledge defense unpersuasive because the claimant
neglected to disclose all the pertinent information to the government). 20 See id. 5
6 The appropriate person within the government did not have the knowledge of the falsity; 21 or The government oᯤcial with knowledge could not have justly acquiesced to
or even condoned the falsity. 22 Reasonable Interpretation A party s reasonable interpretation of an unclear or ambiguous statutory or regulatory provision may negate the
reckless disregard/intent standard of the FCA. 23 Similarly, a plausible contract interpretation negates FCA liability. 24 Reliance on Expert or Counsel The expert advice defense is
available so long as the defendant has made full disclosure of the facts to the expert and is relying on the advice in good faith In United States ex rel. Butler v. Hughes
Helicopter, Inc., a relator argued that the government knowledge defense did not apply because the wrong Army personnel knew, in this case an Army technical representative.
71 F.3d 321, 326 (9th Cir. 1995) (emphasis in original). The relator argued that for the government knowledge defense to apply, contracting oᯤcers capable of modifying the
contract requirements were the only appropriate oᯤcials to possess such knowledge. Id. The Ninth Circuit disagreed and held that the only reasonable conclusion a jury could
draw from the evidence was that [the claimant] and the Army had so completely cooperated and shared all information during the testing that [the claimant] did not knowingly
submit false claims. Id. at 327; see, e.g., United States ex rel. Costner v. United States, 317 F.3d 883, (8th Cir. 2003) (en banc) (ᯤnding that a project manager, engineers, a risk
assessment specialist and other scientists assigned to the work-site were suᯤcient government oᯤcials to invoke the government knowledge defense). 22 See United States v.
Cripps, 460 F.Supp. 969, 974 (D.C. Mich. 1978) (stating that [i]f anyone [] authorized [the claimant] to violate the contract [or contract materials], that person exceeded his or her
authority and the government is not bound by the unauthorized acts of its agents. ); see also United States v. Mack, 2000 WL , *6 (S.D. Tex. 2000) (ᯤnding that agents for a
contractor or state government overseeing a federal program cannot be imputed to the federal government to preclude suit under the FCA. Any such agent purporting to
authorize Defendant to submit false claims was acting outside his or her authority. ) (internal citations omitted). Another argument is that the government oᯤcial acted outside
the scope of his authority or in a ultra vires manner. United States v. Cripps, 460 F.Supp. 969, 974 (D.C. Mich. 1978). 23 See, e.g., Safeco Insurance Co. of America v. Burr, 127 S.
Ct (U.S. 2007); see also Hagood v. Sonoma County Water Agency, 81 F.3d 1465, (9 th Cir. 1996). 24 See, e.g., U.S. ex rel. Hochman v. Nackman, 145 F.3d 109 (9 th Cir. 1998). 6
7 The advice of counsel defense is similarly available but often requires the waiver of the attorney-client privilege. 26 o NOT A DEFENSE THAT AN ORGANIZATION
SUCCESSFULLY PERFORMED THE UNDERLYING CONTRACT OR ACHIEVED THE GOALS OF A GRANT PROGRAM. 27 Qui Tam Actions: o A private individual (i.e., a former-
disgruntled/whistleblower employee) can also bring an FCA action, this is referred to as a qui tam action. 28 o Under this authority, the government can take over (or intervene)
the action, or leave it to the private individual (or relator). 29 If the government intervenes, it has the primary responsibility for prosecuting the action without regard to the
relator s interest. 30 If the government elects not to intervene, the relator has responsibility for prosecuting the action. 31 o The government can also dismiss or settle an action.
32 o Award to relator: If the government intervenes: 25 See, e.g., U.S. v. Butler, 211 F.3d 826, 833 (4 th Cir. 2000). 26 See, e.g., U.S. v. McLennan, 563 F.2d 943, 945 n.2 (9 th Cir.
1977). 27 See U.S. ex rel Longi v. Lithium Power Technologies, Inc. (Nos , ) (5 th Cir., July 9, 2009) (Company liable for $4.9M (three times amount of original grant awards) based
on false representations contained in grant proposals notwithstanding that it successfully designed and developed lithium batteries that were found satisfactory by Dept. of
Defense). 28 See 31 U.S.C. 3730(b)(1). 29 Id. at 3730(b)(4). 30 Id. at 3730(c)(1). 31 Id. at 3730(b)(4)(B). 32 Id. at 3730(c)(2). 7
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8 The relator can receive between 15 and 25% of the proceeds of the action/settlement depending on the contribution, plus expenses. 33 Under some circumstances the court
must limit the relator s proceeds to no more than 10%, plus expenses. 34 If the government does not intervene: The court will determine an amount reasonable that shall not
be less than 25% or more than 30%, plus expenses. 35 OTHER ISSUES: o Implied False Certiᯤcation Theory: Some courts recognize a theory that claims submitted to the
government contain implicit certiᯤcations of regulatory or statutory compliance. 36 Of those courts, many limit this theory to situations where the government s payment is
speciᯤcally conditioned on certiᯤcation of statutory or regulatory compliance. 37 o Reverse False Claims: Section 3729(a)(7) imposes FCA liability for the use of a false statement
or record to conceal, avoid or reduce a payment obligation to the government. 33 Id. at 3730(d)(1). 34 Id. 35 Id. at 3730(d)(2). 36 See, e.g., U.S. ex rel. Pogue v. Diabetes
Treatment Ctrs. of Am., Inc. 238 F. Supp. 2d 258 (D.D.C. 2002). 37 See, e.g., U.S. ex rel. Bowan v. Education Am., Inc., No , 116 Fed. Appx. 531, 2004 WL (5 th Cir. Nov. 30, 2004). 8
9 RECENT DEVELOPMENTS: o Mandatory disclosure of an FCA violation. New Federal Acquisition Regulation rule requires government contractors to timely disclose in writing
when its principles have credible evidence of a violation of federal criminal law involving fraud, conᯤict of interest, bribery, gratuities or the FCA. 38 The disclosure must be made
to both the contracting oᯤcer and the cognizant Inspector General s Oᯤce. 39 Principles include an oᯤcer, director, owner, partner, or a person with primary management or
supervisory responsibilities within a business entity (e.g., general manager, plant manager, head of a subsidiary, division, or business segment, and similar positions). 40 There
are no deᯤnitions for timely or credible evidence in the rule. The preamble to the rule explains with regard to timely that [u]ntil the contractor has determined the evidence to
be credible, there can be no knowing failure to timely disclose. 41 This rule went into eᯤect on December 15, 2008 and is implemented through the inclusion of FAR clause Fed.
Reg. 67,064, 67, (Nov. 12, 2008); codiᯤed at 48 C.F.R Fed. Reg. at 67,091; see also 48 C.F.R (b)(3)(i) Fed. Reg. at 67,090; see also 48 C.F.R (b)(2) Fed. Reg at 67, Id. at 67,
10 However, even if contracts do not include this clause, the rule is still eᯤective because it provides that a non-disclosure can serve as a basis for debarment. 43 o Heightened
scrutiny with American Recovery and Reinvestment Act ( ARRA ). ARRA has fostered wide interest in government contracting and grants. ARRA emphasizes that relevant
Inspectors General be vigilant in ensuring such dollars are not subject to fraud and abuse. o Recent legislation clariᯤying FCA requirements with respect to presentment and
other requirements. (P.L , Sec. 4 (May 20, 2009)). Substantially amends 31 U.S.C by deleting current language specifying that false claim be presented to an oᯤcer or employee
of the United States Government from former 3729(a)(1) and making similar deletions to other subsections of 3729(a). Intended to close perceived loophole resulting from
decision in Allison Engine Co. v. U.S. ex rel. Sanders, No , 2008 WL (U.S. June 9, 2008). Supra at p. 3, n. 12. COMMON PITFALLS FOR NONPROFIT ORGANIZATIONS: o Not
conᯤrming in advance federal contract and grant program-unique requirements. Requirements, especially for grants, can vary signiᯤcantly from programto-program. 43 Id. at
67,091; see also 48 C.F.R
11 o Not ensuring your organization s policies and procedures are consistent with federal requirements. Cost accounting and invoicing not compliant with applicable federal
cost principles. Purchasing and subcontracting/subgranting processes not consistent with federal requirements favoring competition and adequate justiᯤcation for
noncompetitive awards. Ethics, conᯤict of interest, and whistle-blower policies do not mirror federal requirements. o Not ᯤowing down mandatory federal requirements to
subcontractors and subgrant recipients. o Internal controls that are either inadequate to ensure early detection of problems, or are simply not followed. ELEMENTS OF A
SUCCESSFUL COMPLIANCE PROGRAM: o Review and update policies and forms on a regular basis consider an external audit or assessment if it s been a while. Proposal and
Grant Application preparation. Cost Accounting and Billing. 11
12 Government Ethics and Whistleblower policies (ideally, with some provision for anonymous reporting of complaints and potential violations). o Review federal contract,
subcontract, and grant opportunities carefully to identify all requirements and certiᯤcations, including: Required express and implied certiᯤcations in proposal. Cost accounting
and cost principle requirements. Invoicing instructions. o Regular and meaningful training on federal compliance requirements that is tailored to the speciᯤc audience (e.g.,
senior management, cost accounting and billing, business development, contracts and grants management). o Consider exit interviews for former employees. 12
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