ARTICLE · 14 MAY 2019

Cooperation Credit In False Claims Act Cases

Holland & Knight

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Companies facing liability under the False Claims Act (FCA) often desire early resolution with the Department of Justice (DOJ) through settlement

United StatesGovernment, Public Sector

Megan Mocho Jeschke

Caitlin Eberhardt

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Megan Mocho Jeschke is a Partner in the Tysons office

Companies facing liability under the False Claims Act (FCA) often desire early resolution with the Department of Justice (DOJ) through settlement. Hand in hand with the decision to settle comes the decision of whether or not to cooperate.

Cooperation with DOJ can posture a company to receive reduced damages and reduction in statutory penalties in the settlement. Michael Granston, head of the Department of Justice Civil Fraud Section, confirmed during his March 1, 2019 keynote speech at the Federal Bar Association's Qui Tam Conference that DOJ would "meaningfully reward cooperation" in FCA cases. Granston's comments echoed those of Deputy Associate Attorney General Stephen Cox earlier this year. Cox, speaking at an FCA conference in New York, stated that "the Department is committed to rewarding companies that invest in strong compliance programs and who cooperate with our investigations into wrongdoing."

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