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Contractor's Report to OIG Insufficient to Trigger Public Disclosure Bar

Client Alert | less than 1 min read | 03.27.14

In U.S. ex rel Saunders v. Unisys Corp. (E.D. Va.), the court found that the relator's FCA claim was not precluded by the public disclosure bar despite the defendant providing its internal investigation report to OIG because (1) the report failed to reveal allegations or transactions creating an inference of fraud (its conclusion that the alleged fraudulent billing practices were "unacceptable" was not enough) and (2) it was made available only to the DOD IG and the government agency overseeing the contract and not the general public.


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Client Alert | 5 min read | 06.05.26

Grants Overhauled: What the Proposed Rewrite of 2 CFR Part 200 Means for Federal Financial Assistance Award Recipients

The Office of Management and Budget issued on May 29, 2026 a Proposed Rule that would significantly revise the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) at 2 C.F.R. Part 200, potentially impacting the full lifecycle of federal grants, cooperative agreements and other forms of financial assistance, from pre-award merit review through post-award administration and termination. These proposed changes are designed to implement the President’s policy priorities, executive actions related to diversity, equity and inclusion (DEI) activities, and Executive Order No. 14332, Improving Oversight of Federal Grantmaking (EO 14332)....