Davis-Bacon Violation Leads to FCA Liability
Client Alert | less than 1 min read | 10.16.12
On October 1, the Sixth Circuit in United States ex rel. Wall v. Circle C Constr., LLC, affirmed a decision imposing FCA liability when a prime had submitted inaccurate or false payroll certifications that did not properly describe work done by its subcontractors and that also contained hourly wages for subcontractor employees that did not meet federal guidelines for prevailing wages under the Davis-Bacon Act. This opinion serves as an important reminder to primes and subcontractors that failure to comply with minimum wage rate requirements may have significant adverse consequences and also suggests that companies that learn of such violations must carefully consider whether mandatory disclosure pursuant to FAR Subpart 9.4 or 52.203-13 is required.
Contacts
Insights
Client Alert | 8 min read | 04.17.26
CMS Finalizes CY 2027 Medicare Advantage and Part D Rule: Key Implications for Plan Sponsors
On April 6, 2026, the Centers for Medicare & Medicaid Services (CMS) published its final rule governing the Medicare Advantage (Part C) and Prescription Drug Benefit (Part D) programs for Contract Year (CY) 2027. The final rule is effective June 1, 2026, with most provisions applicable to coverage beginning January 1, 2027, and marketing and communications changes taking effect October 1, 2026. Beyond payment, the rule pursues a broad deregulatory agenda aligned with Executive Order 14192, reversing marketing and enrollment safeguards introduced in 2023 and easing documentation and reporting obligations, while introducing new program integrity requirements.
Client Alert | 1 min read | 04.17.26
Client Alert | 3 min read | 04.17.26
Client Alert | 2 min read | 04.16.26
