Bradford Geyer has seen an enforcement agency storm forming around government grants and government procurement and he argues that contractors and grantees would be well served to keep an eye on OIG audit reports that often telegraph enforcement activity. He provides a quick primer regarding a Department of State Office of Inspector General Audit Report regarding Armored Vehicles below:
For reasons I hope to explain more fully in a future column, there could be a perfect storm forming for reinvigorated grant fraud and procurement fraud enforcement (GFPFE) in a Trump Adminisitration. Assuming that is the case, and we wont know for sure for at least another six months, it becomes very important to keep an eye on OIG audits like this one (DOS-OIG Armored Car Audit Report) because audit reports can signal the deployment of investigative resources. Audits can also become a platform for an expanded enforcement initiative or provide a low cost basis for new investigative activity even by other agencies. Armored vehicles is a product market where the government has found procurement problems for close to 15 years and government enforcement agencies have had success at bringing cases in these areas. This is a toxic mix for contractors who should consider doing internal investigations and brushing up on their compliance programs. If they find a problem they should carefully consider a voluntary disclsoure to the appropriate agency(ies).