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DCAA's Use of a Statistically Invalid Analysis for Testing Compensation Reasonableness

Client Alert | less than 1 min read | 02.03.12

The ASBCA in J.F. Taylor, Inc. (Jan. 18, 2012) rejected DCAA’s disallowance of executive compensation, based primarily on the credibility of differing expert opinions. The board concluded that the standard DCAA analysis relying on a “rule of reason” that permits compensation within 10% of the 50th percentile of an unweighted average of multiple surveys with different sample sizes is statistically invalid, at least in part because the contractor’s expert was credible and the government’s, who had included in his resume what was arguably a mail order PhD from a South African “university,” was not.

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Client Alert | 3 min read | 01.21.26

Atlantic Biologicals Opioid DPA: DOJ Continues Ramp Up of Criminal Corporate Healthcare Enforcement

On January 13, 2026, Miami-based pharmaceutical wholesaler Atlantic Biologicals Corporation entered into a two-year DPA, admitting to conspiracy to distribute and dispense controlled substances, including more than 14 million opioid doses to “pill mill” pharmacies in Texas at a markup. The DOJ and DEA underscored the company’s deliberate evasion of compliance checks and disregard for red flags signaling diversion....