DOJ Sets FCA Sights on Private-Sector Colleges
Client Alert | 1 min read | 09.05.12
On August 30, the Justice Department intervened and filed an FCA complaint against ATI Enterprises, Inc., which operates private-sector colleges, alleging that ATI knowingly misrepresented its job placement statistics to maintain its state licensure and, thus, its eligibility for federal financial aid, knowingly enrolled under-qualified students, and fraudulently kept students enrolled despite insufficient attendance and poor grades. DOJ's announcement follows other recent high profile cases in the higher education arena, including US ex rel. Oberg v. Ky. Higher Educ. in June (in which the Fourth Circuit considered whether corporate entities created by states to provide higher education financing, accused of making false claims to DOE, were "persons" subject to FCA liability) and Cuccinelli v. Univ. of Va. in March (in which the Virginia Supreme Court held that UVA was not a "person" or "corporation" under the Virginia state-equivalent FCA).
Contacts
Insights
Client Alert | 3 min read | 05.28.26
Earlier this month, the U.S. Environmental Protection Agency (EPA) withdrew a February 2024 Biden administration proposed rule, “Definition of Hazardous Waste Applicable to Corrective Action for Releases From Solid Waste Management Units,” under the Resource Conservation and Recovery Act (RCRA).[1] The withdrawn proposal would have revised RCRA corrective action regulations to expressly apply the broader statutory definition of “hazardous waste,” rather than only the narrower regulatory definition. Now, EPA is maintaining the status quo for corrective action under RCRA. However, EPA’s withdrawal of its proposed RCRA hazardous waste definition makes no mention of its corresponding proposal from 2024 to list nine per- and polyfluoroalkyl substances (PFAS) as RCRA hazardous constituents.[2] This disjointed withdrawal, while providing some certainty for regulated entities, does not resolve how EPA plans to address PFAS under the RCRA program.
Client Alert | 8 min read | 05.28.26
Texas Targets Big Tech With Wave of Suits and Investigations, Part of Nationwide Trend
Client Alert | 7 min read | 05.27.26
Colorado Hits Reset on AI Regulation: SB 26-189 Repeals and Reenacts the Colorado AI Act
Client Alert | 3 min read | 05.27.26
Don’t Get Left in the Doghouse: The Federal Circuit’s Global K9 Case and the Duty to Intervene
