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Help Wanted: Bounty Hunters

Client Alert | less than 1 min read | 03.22.10

In a memorandum dated March 10, 2010, President Obama directed the heads of all executive departments and agencies to expand their use of recovery audits, now called “Payment Recapture Audits,” in order to identify and reclaim from contractors the funds associated with improper payments (e.g., duplicate payments, payments for services not rendered, overpayments, and payments to fictitious vendors) and has also directed OMB to develop guidance within 90 days for carrying out the requirements of the memorandum. He points approvingly to use of professional and specialized auditors whose compensation is tied to their findings of such overpayments.

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Client Alert | 2 min read | 09.18.25

FDA Announces Intention to Initiate an Aggressive Enforcement Campaign Against Misleading Pharmaceutical Advertising

On September 9, 2025, the U.S. Department of Health and Human Services (HHS) and the Food and Drug Administration (HHS) issued a news release announcing an “aggressive[]” “crackdown” on direct-to-consumer pharmaceutical advertising. This release came on the heels of a Presidential Memorandum President Trump issued the same day directing HHS to “ensure transparency and accuracy in direct-to-consumer prescription drug advertisements,” and the FDA to “take action to enforce legal requirements that advertisements for prescription drugs be truthful and not misleading.”...