The House Ways and Means Committee unanimously approved House Resolution 7959, the IRS Whistleblower Program Improvement Act, marking a significant step towards IRS whistleblower program reform. This bill aims to streamline IRS whistleblower awards, protect whistleblowers’ anonymity, and improve transparency around the largest tax avoidance schemes. For companies, individuals, and tax fraud enforcement advocates, the legislation signals a meaningful shift in how the government incentivizes and protects those who expose wrongdoing. How the IRS Whistleblower Program Currently Works The tax whistleblower program determines awards in two…
The False Claims Act emerged from Civil War-era fraud stemming from fast-paced government spending. Over 150 years later, those same dynamics of large-scale public funding and rapid deployment, which can increase the risk of fraud, continue to shape modern false claims enforcement and highlight the importance of whistleblowers. The Origins of the False Claims Act The False Claims Act (FCA) was signed into law 163 years ago by President Abraham Lincoln. Passed during the Civil War, it was designed to curb wartime fraud…
Artemis II launched on April 1, 2026, sending four astronauts on a lunar flyby and ultimately breaking the record for the farthest distance humans have traveled from Earth. Artemis II is also the first crewed mission beyond low Earth orbit since the Apollo 17 mission in December, 1972. The crew has also captured our hearts by unofficially naming a new lunar crater after Commander Reid Wiseman’s late wife, Carroll, and shared an emotional group hug. Behind every historic space mission is a vast supply chain of contractors and supporting…
What is import fraud, and how does it occur in manufacturing and supply chains? Import fraud (also referred to as “customs fraud”), which has fallen under the spotlight of the Department of Justice, is any attempt to evade duties, taxes, or trade regulations. This is commonly achieved through deceptive or falsified import documentation. In the manufacturing and supply chains sector, this can be done in several ways: such as undervaluing goods, misrepresenting the…
What is the Anti-Kickback Statute? The Anti-Kickback Statute (“AKS”) (42 U.S.C § 1320a-7b(b)), is a federal law that prohibits healthcare providers from knowingly and willfully offering or accepting any form of remuneration to induce or reward patient referrals for services covered by federally funded health programs, including Medicaid, Medicare, or TRICARE also known as a “kickback.” Remunerations refer to anything of value such as a gift, money, or service, offered as a form of bribery whether in a direct or indirect, overt or covert, in cash or in-kind manner. The AKS is an intent-based statute that requires a…
On January 1st, Small Business Administration (SBA) Administrator Kelly Loeffler announced on X that the agency suspended “6,900 Minnesota borrowers” over suspected fraudulent activity regarding the Paycheck Protection Program (PPP) and Economic Injury Disaster Loan (EIDL) payouts. Loeffler reported that these loans are worth “approximately $400M.” This article will explore PPP EIDL programs, relevant fraudulent claims in Minnesota, and how these illegally acquired loans violate the False Claims Act (FCA). How…
On January 16th, the Department of Justice (“DOJ”) released the False Claims Act report for the 2025 fiscal year. The report spotlights that settlements and judgments under the False Claim Act exceeded $6.8 billion, the highest amount in a single year since the history of the False Claims Act. This was largely due to the record-breaking number of qui tam lawsuits, also known as whistleblower actions, filed. The 1,1297 qui…
Traditions Settlement Overview Traditions Health LLC announced their $34 million settlement to resolve allegations under the False Claims Act (“FCA”), Anti-Kickback Statute (“AKS”), and Physician Self-Referral Law (“Stark Law”) on January 22, 2026. The settlement is in response to violations involving billing Medicare for medically unnecessary home health claims and giving benefits to physicians in exchange for patient referrals. Traditions’ alleged wrongdoings occurred between 2019 and 2024 at several locations across Oklahoma and Texas. The healthcare company self-disclosed the details of…
With the announcement of a Department of Justice (“DOJ”) Corporate Whistleblower Awards Pilot Program earlier this year, enforcement of the Foreign Corrupt Practices Act (“FCPA”) has emerged as a new priority for DOJ whistleblower investigations. Under the new program, whistleblowers submit information that results in a successful prosecution may be eligible to receive a percentage of the resulting settlement. In this article, we will discuss the five largest FCPA awards as well as background on the FCPA. The Foreign Corrupt Practices Act The Foreign Corrupt Practices Act of…
While government shutdowns temporarily affect the pace of whistleblower investigations, enforcement under the False Claims Act and related programs remain resilient. Agencies like the Department of Justice, SEC, CFTC, and IRS continue to prioritize critical fraud detection and case preparation, even with limited staffing. How do Government shutdowns temporarily affect False Claims Act investigations and DOJ litigation? The Department of Justice (DOJ) maintains a Government shutdown employee furlough exception that applies to 89% of their workforce for the first 5 days of a Government shutdown. In the most recent Government shutdown, the DOJ was required to substantially limit all operations without compromising to a significant degree…
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