False Claims Compliance Programs
False Claims Act cases can often be avoided—or their consequences minimized—through the establishment of effective compliance programs. Long before enactment in 1991 of the Federal Sentencing Guidelines, which recognized the value of corporate compliance programs, we were already assisting clients in the design and implementation of these programs. In fact, we pioneered the concept of corporate compliance programs and compliance reviews in the late 1970s. Since that time, we have conducted compliance reviews, established compliance programs, drafted Codes of Conduct and Compliance Policies, and provided compliance training for well over 200 clients, in almost every industry. Our clients call us when they are:
- Considering measures to prevent and detect noncompliance and misconduct and to mitigate the chances of facing a lawsuit under the False Claims Act
- Undertaking steps to avoid suspension or debarment from government contracting or other government programs (such as Medicare or Medicaid)
- Considering undertaking an internal investigation or a “voluntary disclosure”
- Faced with responding to a grand jury subpoena, agency Inspector General subpoena, or Department of Justice Civil Investigative Demand