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It’s Back – DCAA’s Non-Defense Audit Authority Revived

Client Alert | less than 1 min read | 11.03.16

A recent DCAA policy memorandum lifted the moratorium on DCAA performing non-Defense audits, which (as discussed here) effectively applied only to incurred cost audits. Specifically, because DCAA has purportedly "met the requirement of less than 18 months of incurred cost inventory" outlined in the 2016 National Defense Authorization Act as of October 1, 2016, DCAA "may again provide full audit support for non-Defense agencies" and the Operations Directorate "has coordinated at the Executive level with [its] reimbursable customers to inform them that [its] audit services can resume."

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Client Alert | 3 min read | 11.21.25

A Sign of What’s to Come? Court Dismisses FCA Retaliation Complaint Based on Alleged Discriminatory Use of Federal Funding

On November 7, 2025, in Thornton v. National Academy of Sciences, No. 25-cv-2155, 2025 WL 3123732 (D.D.C. Nov. 7, 2025), the District Court for the District of Columbia dismissed a False Claims Act (FCA) retaliation complaint on the basis that the plaintiff’s allegations that he was fired after blowing the whistle on purported illegally discriminatory use of federal funding was not sufficient to support his FCA claim. This case appears to be one of the first filed, and subsequently dismissed, following Deputy Attorney General Todd Blanche’s announcement of the creation of the Civil Rights Fraud Initiative on May 19, 2025, which “strongly encourages” private individuals to file lawsuits under the FCA relating to purportedly discriminatory and illegal use of federal funding for diversity, equity, and inclusion (DEI) initiatives in violation of Executive Order 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity (Jan. 21, 2025). In this case, the court dismissed the FCA retaliation claim and rejected the argument that an organization could violate the FCA merely by “engaging in discriminatory conduct while conducting a federally funded study.” The analysis in Thornton could be a sign of how forthcoming arguments of retaliation based on reporting allegedly fraudulent DEI activity will be analyzed in the future....

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