False Eligibility Application For Grant May Violate FCA
Client Alert | 1 min read | 11.09.05
In a ruling that could expand the exposure of grantees to False Claims Act liability, the Seventh Circuit in United States ex rel. Main v. Oakland City University (Oct. 20, 2005) held that a relator stated an FCA claim based upon a private university's allegedly false representation, made on a "phase one" application to establish institutional eligibility for federal financial aid, that it would comply with laws prohibiting payment of incentive fees to recruiters for enrolling students. Rejecting the argument that the "phase one" application does not by itself seek any payment, the court reasoned that a false "phase one" eligibility application could be actionable as a "false record or statement" under the FCA because it supports subsequent "phase two" requests for specific loans and grants.
Insights
Client Alert | 4 min read | 02.05.26
EU–Brazil Mutual Adequacy: A Milestone for Global Data Flows and Latin America’s Digital Positioning
On January 27, the EU and Brazil announced their positive determination on the mutual adequacy of Brazil’s and the EU’s data privacy frameworks — confirming the growing importance of transatlantic data transfers and the EU-Mercosur relationship. This adequacy decision, while not formally tied to the EU-Mercosur trade negotiations, is a historic development that can facilitate cross-border data transfers and fuel shared economic growth driven by data-centered service sectors.
Client Alert | 4 min read | 02.04.26
DOJ Antitrust Division Issues First-Ever Award Under Whistleblower Rewards Program
Client Alert | 4 min read | 02.04.26
New York District Court Confirms Insurance Coverage Must Mean Something
Client Alert | 13 min read | 02.04.26
