1. Home
  2. |Insights
  3. |Weeding Out Bad Contractors -- The Government's Push to Enhance its Suspension and Debarment Function

Weeding Out Bad Contractors -- The Government's Push to Enhance its Suspension and Debarment Function

Client Alert | 1 min read | 11.17.11

On November 15, 2011, the head of OMB, Jacob Lew, issued a memorandum requiring the heads of executive departments and agencies to increase management attention on suspension and debarment, consistent with the policies and procedures in the FAR. On the heels of the OMB memorandum, the U.S. Senate's Committee on Homeland Security and Governmental Affairs convened hearings on November 16 on "Weeding Out Bad Contractors," which featured testimony from, among others, Daniel Gordon, the Administrator for Federal Procurement Policy; David Sims, the Chair of the ISDC; and Steven Shaw, the Air Force’s debarment and suspension official.

For further analysis and links to the OMB Memo and Congressional testimony, click here for a related blog post by Daniel Forman.

Contacts

Insights

Client Alert | 8 min read | 03.05.26

Fifth Circuit Decision in Health Care Fraud Case Highlights Importance of Careful Drafting in Civil RICO Complaints

A recent decision by the United States Court of Appeals for the Fifth Circuit, Farmers Texas County Mutual Insurance Co. v. 1st Choice Accident & Injury, LLC, No. 24-20275 (5th Cir. Feb. 24, 2026), offers important lessons for health care payors and other potential plaintiffs considering civil claims under the federal Racketeer Influenced and Corrupt Organizations Act (RICO). Although the Fifth Circuit’s decision focused on a procedural issue, the underlying case turned on a fundamental pleading failure: the plaintiff insurers did not adequately describe the fraudulent network they were suing as a RICO “enterprise.” The result was dismissal of a $14 million fraud case....