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Additional Business Systems Reviews Proposed

Client Alert | less than 1 min read | 07.17.14

The government issued a proposed rule on Monday that would require contractors subject to withholdings under the Business Systems Rules to conduct annual internal reviews of their accounting, estimating, and material management and accounting business systems and engage an independent CPA firm to conduct audits every three years (or more frequently if directed by the contracting officer). The proposed rule if adopted as drafted would likely result in inefficiency and delay because it contemplates DCAA review and approval of the independent CPA work plan, audit, and workpapers and permits DCAA to challenge the findings of the independent CPAs.


Insights

Client Alert | 6 min read | 11.19.25

Buying Peace: The Importance of Releasing FCA Liability When Resolving Criminal Allegations of Fraud Against the Government

The facts before the Third Circuit in the recently decided case of Patel v. United States illustrate how parties can put themselves in a bind if they make factual admissions when resolving a criminal case involving fraud on the government while not simultaneously resolving the government’s civil claims under the False Claims Act (FCA) for the same underlying conduct....