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Costs Of Influencing Collective Bargaining Decisions Proposed For Disallowance

Client Alert | less than 1 min read | 04.22.10

To implement the provisions of Executive Order No. 13494, Economy in Government Contracting, the FAR Council has proposed changes to the labor relations cost principle, FAR 31.205-21, expressly to disallow the costs of activities to persuade employees to exercise or not to exercise their collective bargaining rights, such as the costs of preparing and distributing materials, legal and consultant fees, costs of meetings (including salaries of attendees), and planning and conducting activities by managers, supervisors, or union representatives during working hours. Comments on the proposed rule are due June 14, 2010.

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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....