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Expanding FAPIIS: First "Ownership," Now "Predecessors"

Client Alert | less than 1 min read | 12.17.14

On December 4, 2014, the FAR Councils issued a proposed rule that would require offerors to disclose all "predecessor" entities that held a federal contract or grant within the prior three years, with comments due by February 2, 2015. This information, in addition to the recent addition of ownership information, will be stored in the Federal Awardee Performance and Integrity Information System (FAPIIS).


Insights

Client Alert | 4 min read | 04.16.26

ROI Tracking as Mens Rea? Novartis Ruling Reframes AKS Pleading Risk

Is evidence that a company tracked return on investment (ROI) for certain actions and expenses sufficient to prove mens rea and plead a violation of the federal Anti-Kickback Statute (AKS) with the requisite particularity? A recent decision in the U.S. District Court for the Southern District of New York (SDNY) suggests that it is....