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Agencies Abuse Sole-Source Process

Client Alert | less than 1 min read | 02.20.13

On the heels of the CFC in Innovation Dev. Enters. of Am., Inc. v. U.S. (Jan. 29, 2013) finding that the Air Force had done zero advance planning before improperly justifying retention of the multiyear incumbent on a sole-source basis, the GAO issued its study faulting DOD more generally. In reviewing eight large sole-source awards, GAO found that DOD in six of them had failed to adhere to the recently tightened FAR requirements for sole-source buys.


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Client Alert | 7 min read | 10.27.26

New Developments in DOJ Whistleblower Policies and HHS Disclosures: Key Takeaways for General Counsel, Chief Compliance Officers, and Boards

On October 20, 2026, the U.S. Department of Justice’s (DOJ) National Fraud Enforcement Division announced a new whistleblower rewards initiative, the Fraud Whistleblower Incentive Program (WHIP). Assistant Attorney General Colin M. McDonald issued a directive earlier this month directing Division leadership to design and implement policies and programs that incentivize whistleblowers to bring forward credible information pertaining to fraud. The new WHIP incentive pays awards of $10,000 to $30,000 for qualifying tips at or around the time criminal charges are filed or unsealed, rather than years later at case resolution....