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First Pandemic Response Accountability Committee Report Emphasizes Government-Wide Concerns About Fraud and Grant Management

Client Alert | 1 min read | 06.19.20

On Wednesday, June 17, 2020, the Pandemic Response Accountability Committee (“PRAC”), composed of 21 Offices of Inspector General overseeing agencies that received the most CARES Act funds, released its first report, “Top Challenges Facing Federal Agencies: COVID-19 Emergency Relief and Response Efforts.”  The report was derived from information provided by 37 Offices of Inspector General from across the government.  PRAC is responsible for leading OIG CARES Act funding oversight.  Although the report flags concerns ranging from ballot theft to staffing shortages, the primary challenge identified in the report is the potential for fraud and abuse of Government funding under various programs.  The report emphasizes compliance and oversight concerns unique to the large amount of funding (~$2.4 trillion) appropriated under the CARES Act (and other COVID-19 legislation) in conjunction with the need to distribute these funds quickly in the midst of reduced or altered agency staffing and operations due to COVID-19.  With 37 Inspectors General asserting their commitment to addressing improper payments and fraud, companies should prioritize compliance now and ensure traceability of grant and contract monies associated with COVID-19 to prepare to respond to audits and reduce the risk of an investigation in the coming year. 

Further commentary on the concerns regarding fraud and abuse identified in the PRAC report, including related to potential violations of the federal False Claims Act, will be forthcoming.

Insights

Client Alert | 4 min read | 03.25.26

NAIC Intensifies AI Regulatory Focus: What Health Insurance Payors Need to Know

The National Association of Insurance Commissioners (NAIC) is intensifying its oversight of how insurers use AI — and the pace of regulatory activity shows no signs of slowing. Over the past several months, the NAIC has published a formal Issue Brief staking out its position on federal AI legislation, launched a multistate AI Evaluation Tool pilot aimed at examining insurers’ AI governance programs, and continued to expand adoption of its AI Model Bulletin across state lines. These developments continue a trend towards enhancing regulation; the NAIC adopted AI Principles in 2020 and a Model Bulletin in 2023 clarifying that existing insurance laws apply to AI systems and establishing expectations for governance, documentation, testing, and third-party oversight. That Model Bulletin has now been adopted in approximately 24 states....