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Cormac Connor

As seen in: Law360, JD Supra, LexBlog
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Articles

DOJ Announces Significant Policy Shifts on Sub-Regulatory Guidance and Qui Tam Dismissals

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By Jonathan Porter, Jody Rudman, Cormac Connor
| LexBlog
Executive Summary On September 18, 2026, the Department of Justice (DOJ) announced two substantial revisions to the Justice Manual that will materially affect False Claims Act (FCA) enforcement and defense strategy: Guidance Documents: DOJ will no longer treat sub-regulatory guidance (CMS manuals, FDA interpretive memos, etc.) as creating independently enforceable legal obligations in FCA cases. The government must prove violations of statutes, regulations, or contracts.
Open in Who Shared Issue with article?

Construction Sector Compliance and Reporting Certifications: Evolving False Claims Act Liability

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By Cormac Connor, Todd Gee
| JD Supra
Construction companies working on projects that involve federal funds are typically aware that they can be at risk of False Claims Act (FCA) suits for inaccurate billing or false statements about construction quality. The Department of Justice (DOJ) has broadened its FCA focus beyond those areas by targeting the compliance certifications and regulatory statements companies make in connection with government contracts, grants, loans, and other federally funded programs.
Open in Who Shared Issue with article?

Construction Sector Compliance and Reporting Certifications: Evolving False Claims Act Liability

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By Cormac Connor, Todd Gee, Kip Randall
| LexBlog
Construction companies working on projects that involve federal funds are typically aware that they can be at risk of False Claims Act (FCA) suits for inaccurate billing or false statements about construction quality. The Department of Justice (DOJ) has broadened its FCA focus beyond those areas by targeting the compliance certifications and regulatory statements companies make in connection with government contracts, grants, loans, and other federally funded programs.
Open in Who Shared Issue with article?
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