Woman Pleads Guilty To Theft Concerning Programs Receiving Federal Funds

Thursday, July 27, 2017

SAN JUAN, P.R. – Zoraida Velázquez-Bracero plead guilty to an information charging her with theft concerning programs receiving federal funds, announced Rosa Emilia Rodríguez-Vélez, United States Attorney for the District of Puerto Rico. The U.S. Department of Education, Office of Inspector General was in charge of the investigation.

From June 2005 until July, 2015, Velázquez-Bracero was the Purchasing Director at Pontifical Catholic University of Puerto Rico, an entity that receives in excess of $10,000.00 in federal funding in a one year period. In this position, Defendant was issued a University corporate credit card for purchasing goods and supplies for the University as well as arranging official travel for University professors. However, in 2008 Defendant started using this corporate credit card for personal expenses not authorized by the University.

Through direct charges and cash advances, Velázquez-Bracero used this corporate credit card to pay for school tuition, household utility bills and other items, and vacations to Disney World, New York City, Atlanta, Indianapolis, Canada, and France. Defendant concealed the use of this corporate credit card by altering and/or creating fictitious credit card statements wherein she hid the charges by increasing the amounts of other legitimate charges to the card, or by deleting the charges altogether before submitting the statement to the finance department for payment.

Although the original limit on this corporate credit card was $80,000.00, Velázquez-Bracero obtained numerous credit limit increases by forging her supervisor’s signature on letters to the credit card company requesting said increases. Defendant knew that she was affecting federal grants when she illegally used this corporate credit card. The total amount of unauthorized charges by Velázquez-Bracero was $655,432.00.

“The defendant misappropriated funds intended to aid University students, for her illegal personal gain,” said US Attorney Rosa Emilia Rodríguez-Vélez. “At the U.S. Attorney’s Office we will continue to aggressively investigate and prosecute financial crimes. This arrest should discourage those who get involved in these types of schemes before it’s too late, because we will continue investigating and prosecuting these offenses.”

“Federal education funds exist to provide students with educational opportunities and help students make their dreams of higher education a reality, it’s not a personal slush fund,” said Yessyka Santana, Special Agent in Charge of the U.S. Department of Education Office of Inspector General Southeast Regional Office. “I’m proud of the work of OIG special agents, our law enforcement partners, and the PCUPR staff for holding Ms. Velázquez accountable for her alleged criminal actions.”

As a result of the guilty plea, the defendant may be sentenced to a term of eight to fourteen months in prison, a fine not to exceed two hundred fifty thousand dollars ($250,000.00), and/or a term of supervised release of not more than three (3) years. Assistant United States Attorney Scott H. Anderson is in charge of the prosecution of the case.

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Former Worksource DeKalb Supervisor Charged with Bribery

Wednesday, July 19, 2017

ATLANTA – Roderick L. Wyatt, 61, of Stone Mountain, Ga., has been charged with accepting bribe payments in exchange for approving the enrollment of almost 20 students to a local college, through a federal workforce program in DeKalb County. The federal indictment alleges that Wyatt agreed to accept payments from the college president for each student sent to the college through Worksource DeKalb, a federally funded program.

“Wyatt allegedly sold his supervisory position with WorkSource DeKalb for cash. In doing so, he allegedly accepted a “bounty” for each student sent to a specific college,” said U. S. Attorney John A. Horn.

“An important mission of the Office of Inspector General is to investigate allegations of fraud relating to Workforce Innovation and Opportunity Act grants issued by the U.S. Department of Labor. We will continue to work with our law enforcement partners to investigate these types of allegations,” said Rafiq Ahmad, Special Agent in Charge, Atlanta Region, U.S. Department of Labor, Office of Inspector General.

Public corruption is the FBI’s top criminal investigative priority because it takes a significant toll on the public’s pocketbooks by siphoning off tax dollars,” said FBI Special Agent in Charge David J. LeValley. “This case is another example of our commitment to combat corruption by investigating public officials who choose to abuse federally funded programs.”

According to United States Attorney Horn, the charges, and other information presented in court: the Workforce Innovation and Opportunity Act is a federal public law designed to improve and modernize America’s workforce development system by providing dislocated and low-income individuals with the skills and education needed to obtain employment and by providing employers with trained and qualified workers to fill employment vacancies.

WorkSource DeKalb (formerly DeKalb Workforce Development) was a DeKalb County department funded exclusively by the federal Workforce Innovation and Opportunity Act. WorkSource DeKalb (“WSD”) served the unemployed and underemployed citizens of DeKalb County by providing work readiness programs, services, and activities necessary to obtain sustainable wages. Using federal funds, WSD paid the cost for unemployed and underemployed individuals to attend pre-screened schools or programs where the individuals gained the technical or vocational skills needed to obtain employment in fields such as nursing, truck driving, or welding. After reviewing the unemployed individuals’ career aspirations and educational interests, WSD staff members recommended the individuals to particular pre-screened schools or programs.

From 2013 to April 2017, Wyatt served as a WSD Employment and Training Supervisor. As a supervisor, Wyatt reviewed and approved the school/program recommendations made by WSD staff members.

In 2014, the president and founder of a pre-screened school that offered its students nursing assistant and medical technician certifications approached Wyatt and offered to pay him for each individual that WSD referred to the College. In 2014 and 2015, Wyatt approved the enrollment of approximately 19 students to the College. The College’s president paid Wyatt $100 for each student approved to attend his school. In total, the College received approximately $82,000 in federal funds under the Workforce Innovation and Opportunity Act. The name of the college has not been identified in the Information or any of the court pleadings.

This case is being investigated by the Department of Labor – Office of the Inspector General and Federal Bureau of Investigation.

Assistant United States Attorney Jeffrey W. Davis and Special Assistant United States Attorney Tyler Man prosecuting the case.

For further information please contact the U.S. Attorney’s Public Affairs Office at USAGAN.PressEmails@usdoj.gov or (404) 581-6016. The Internet address for the U.S. Attorney’s Office for the Northern District of Georgia is http://www.justice.gov/usao-ndga.

Putnam Co. Woman Charged with TennCare Drug Fraud

Friday, July 14, 2017

NASHVILLE, Tenn. – A middle Tennessee woman is charged with TennCare fraud involving the sale of prescription drugs which were obtained through TennCare benefits.

The Office of Inspector General (OIG) today announced the arrest of Kimberly Ann Smith, 31, of Cookeville, after a joint investigation with the Baxter Police Department.

Smith is charged with TennCare fraud for allegedly obtaining a prescription for the painkiller Oxycodone during a clinical visit paid for by TennCare, and later selling a portion of the drugs.

“We are working with municipal and county police officers across the state, as they often discover a connection to TennCare during local drug investigations,” Inspector General Manny Tyndall said.  “Local police are clearly committed to eliminating prescription drug abuse, and we’re doing our part to stop abusers who are supporting this lifestyle with TennCare.”

District Attorney General Bryant C. Dunaway is prosecuting. TennCare fraud is now a Class D felony punishable by up to four years in prison per charge.

The OIG, which is separate from TennCare, began full operation in February 2005 and has investigated cases leading to more than $3 million being repaid to TennCare, with a total estimated cost avoidance of more than $163.6 million for TennCare, according to latest figures. To date, 2,871 people have been charged with TennCare fraud.

Through the OIG Cash for Tips Program established by the Legislature, Tennesseans can get cash rewards for TennCare fraud tips that lead to convictions. Anyone can report suspected TennCare fraud by calling 1-800-433-3982 toll-free from anywhere in Tennessee, or visit the website and follow the prompts that read “Report TennCare Fraud.”

Owner of Home Health Agency and Employee Arrested for Allegedly Stealing Nearly $2.7 Million From MassHealth

July 11, 2017

Defendants Charged with Routinely Overbilling MassHealth, Falsely Billing for Unauthorized Services that Were Never Provided

BOSTON – The owner of a Boston-based home health agency and an employee have been arrested in connection with allegedly stealing nearly $2.7 million from the state’s Medicaid program (MassHealth) by routinely overbilling and falsely billing for services that were not authorized or provided to patients, Attorney General Maura Healey announced today.

Elena Kurbatzky, age 44, of Boston, and Natan Zalyapin, age 43, of Burlington, were arrested last night by Massachusetts State Police assigned to the AG’s Office. A Suffolk County Grand Jury returned indictments charging Kurbatzky, Zalyapin and the company, Harmony Home Health Care, LLC (Harmony), on Monday.

“We allege that these defendants stole millions of MassHealth funds meant to provide health care for those in need,” said AG Healey. “My office is committed to protecting Medicaid from fraud and abuse.”

Kurbatzky was indicted on charges of Medicaid False Claims (3 counts), Larceny over $250 by False Pretenses (3 counts), and Medicaid Member Eligibility Fraud (1 count). Zalyapin was indicted on charges of Medicaid False Claims (2 counts) and Larceny over $250 by False Pretenses (2 counts). Harmony was indicted on charges of Medicaid False Claims (3 counts) and Larceny over $250 by False Pretenses (3 counts).

Kurbatzky and Zalyapin were arraigned in Suffolk Superior Court today where they pleaded not guilty to the charges. Zalyapin was released on personal recognizance and Kurbatzky was transferred to Boston Municipal Court on an outstanding warrant.

As conditions of their release, they must surrender their passports, be monitored by GPS, not travel outside of the state, check in weekly with the Probation Department, stay away from witnesses in the case, and not provide or bill for MassHealth services. They are scheduled to appear in Suffolk Superior Court for a hearing on Aug. 8.

The company will be arraigned in Suffolk Superior Court on Aug. 8.

Harmony is a home health agency located on Albany Street in Boston and Kurbatzky is the sole owner. The agency was established to provide home health services to individuals covered by the MassHealth program, including skilled nursing, home health aide visits and physical, occupational, and speech therapies. Kurbatzky and Zalyapin are both registered nurses and allegedly provided the majority of nursing services to Harmony’s patients.

The AG’s Office began an investigation after the matter was referred by MassHealth, which suspected misconduct and fraudulent billing practices.

The AG’s investigation revealed that between February 2015 and October 2016, Harmony billed MassHealth for home health services allegedly provided to 38 patients, but either provided no services to those patients or billed for more services than were actually provided.

Specifically, authorities allege that on numerous instances, Harmony billed MassHealth for nurses who allegedly provided services to several patients in different locations at the exact same time, so those services could not physically have been performed as claimed.

The defendants also billed MassHealth for services that were not authorized by physicians and, in many cases, forged physician signatures on the patient plans of care in an attempt to show the services were authorized.

The defendants allegedly billed for services never provided to MassHealth members, including instances where the company billed for home health services while members were at inpatient facilities. Kurbatzky and Zalyapin also billed MassHealth for services that were not provided while they were traveling or while Zalyapin was working at other jobs.

The defendants billed for physical, occupational, and speech therapy for the majority of Harmony’s MassHealth patients even though the services were not authorized by the patients’ physicians and Harmony did not employ licensed therapists to perform the alleged services.

Kurbatzky also allegedly made false statements or failed to disclose material facts in order to make herself eligible for MassHealth. She then allegedly billed MassHealth for services she purportedly received from Harmony that were not authorized by a physician.

Based on these various schemes, the AG’s Office alleges that the defendants defrauded MassHealth of nearly $2.7 million dollars.

MassHealth provides healthcare products and services to eligible low-income individuals, including people with disabilities, children and senior citizens.

All of these charges are allegations and defendants are presumed innocent until proven guilty.

This matter was handled by Assistant Attorneys General Jennifer Goldstein and Kevin Lownds and Investigators Christine Baker and Megan Corrigan, all of AG Healey’s Medicaid Fraud Division, with assistance from the Massachusetts State Police assigned to the AG’s Office, Victim Witness Advocate Amber Anderson, of the AG’s Victim Services Division, and the Office of the Inspector General. MassHealth provided invaluable assistance during this investigation.

12 Debarred Over Role in Syria Humanitarian Aid Fraud Scheme

May 26, 2017

Washington, D.C.—The U.S. Agency for International Development (USAID) Office of
Inspector General (OIG) announced the debarment of 12 companies and individuals over their participation in a fraud scheme affecting humanitarian aid in Syria. USAID officials made the decision in April barring Orhan Senkardes, the Senkardes Company, and certain related individuals and companies from future business with the
U.S. Government for 5 years.

USAID OIG, which has been investigating corruption in cross-border humanitarian aid programs in Syria since 2015, provided information that led to USAID’s debarment action. “OIG’s pursuit of corrupt actors in Syria and the surrounding region remains as critical as ever as we work to protect life-saving aid programs from fraud, waste, and abuse,” said Ann Calvaresi Barr, USAID Inspector General. “I commend our special agents for their tenacity, insight, and continued dedication to our investigative efforts and recognize USAID’s willingness to take decisive action to protect taxpayer resources based on OIG’s work.” The OIG’s investigation is open and ongoing.

USAID’s debarment of the 12 companies and individuals applies across the U.S. Government. OIG’s investigative work contributed to the decision, establishing that Orhan Senkardes, the Senkardes Company, and Mr. Senkardes’ affiliated companies or personnel participated in a procurement fraud scheme with corrupt nongovernmental organization staff, including Luan Meraku, who implemented USAID-funded programs. Further, investigative results revealed that although the Senkardes Company, Selkas, Forvet, and Yigit Motorlu companies were all under Mr. Senkardes’ control, they bid against each other for U.S.-funded procurements under the appearance of fair and open competition. The debarred companies and affiliated individuals are:

  • Senkardes Gida San ve Tic Ltd.
  • Selcuk Benli
  • Forvet
  • Ismet Kalin
  • Selkas
  • Hecran Kalin
  • Yigit Motorlu
  • Zerrin Nalbanoglu
  • Orhan Senkardes
  • Erol Senkardes
  • Luan Meraku
  • Erdal Senkardes

The U.S. Government’s System for Award Management (SAM), www.sam.gov, provides further information on each of the debarred entities and individuals, which are currently excluded from transactions with U.S. Government departments, agencies, and contractors.

To date, OIG’s investigations in Syria and the surrounding region have identified a
network of commercial vendors and nongovernmental organizations employees who
colluded to engage in bid-rigging and multiple kickback schemes related to Syrian
humanitarian aid awards. The investigations to date have led to $239 million in
suspended program funds; 35 agency suspension or debarment decisions; 19 personnel resignations, terminations, or suspensions; and $19.6 million in savings for USAID.

Throughout the course of investigations, OIG coordinates closely with USAID’s Bureau
for Management, Office of Management Policy, Budget, and Performance, Compliance
Division. The division is responsible for making recommendations on potential
suspension and debarment actions to the agency.

Protecting humanitarian operations from organized crime is a top priority for USAID
OIG’s Office of Investigations. In addition to aggressively investigating allegations,
USAID OIG has also published a fraud awareness handbook and is actively engaged in providing fraud awareness training within the industry. The handbook, Compliance and Fraud Prevention: A Pocket Guide for the Middle East Crisis Humanitarian Response, can be found on OIG’s web site.

Anyone with information about suspected fraud, waste, or abuse in USAID programs in Syria and around the world is urged to contact USAID OIG directly.
Telephone
+1 (800) 230-6539 or +1 (202) 712-1023
Email
Syria Investigations Team: syriaoiginv@usaid.gov

General: ig.hotline@usaid.gov

Online, via OIG’s public web site
https://oig.usaid.gov/content/oig-hotline
Information reported to OIG is treated in confidence and OIG protects the identity of
each person providing information to the maximum extent provided by law.
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Misr Sons Development S.A.E. Agrees to Pay $1.1 Million to Resolve False Claims Act Allegations

Tuesday, June 13, 2017

Misr Sons Development S.A.E. (Hassan Allam Sons, “HAS”), a construction company with its principal place of business in Cairo, Egypt, has agreed to pay $1.1 million to settle allegations that HAS submitted false claims in connection with U.S. Agency for International Development (USAID) contracts, the Justice Department announced today.

“Contractors who misrepresent their eligibility for government contracts undermine the government procurement process,” said Deputy Assistant Attorney General Joyce R. Branda of the Civil Division. “The Justice Department will take action to protect that process and to ensure that taxpayer funds are not misused.”

“USAID Office of Inspector General extensively investigated this matter and thanks the Department of Justice for its tenacity and dedication,” said Special Agent in Charge Jonathan Schofield of USAID Office of Inspector General. “Total settlements on this matter exceed $10 million and demonstrate once again that the United States expects its contractors to execute their awards in accordance with all requisite terms and conditions, whether operating domestically or overseas.”

The settlement concerns USAID-funded contracts for the construction of water and wastewater infrastructure projects in the Arab Republic of Egypt in the 1990s. The contracts were awarded to a joint venture partnership that included Washington Group International Inc. (WGI), Contrack International Inc. (Contrack) and HAS. The United States filed suit under the False Claims Act and the Foreign Assistance Act, alleging that HAS was ineligible to participate in the joint venture but that its participation was concealed from USAID. As a result, HAS and its partners allegedly received USAID-funded contracts to which they were not entitled. The settlement resolves only HAS’ liability. The United States previously settled with Contrack and WGI.

This settlement was the result of a coordinated effort by the Civil Division’s Commercial Litigation Branch, the U.S. Attorney’s Office for the District of Idaho and the USAID Office of Inspector General.

The case is captioned United States v. Washington Group International Inc. f/k/a/ Morrison Knudsen, Corporation, Contrack International, Inc.; and Misr Sons Development S.A.E. a/k/a Hassan Allam Sons, No. 04-555 (D. Idaho). The claims resolved by this settlement are allegations only and there has been no determination of liability.

Virginia Man Admits to Falsely Certifying Bridge Inspection Vehicles

Friday, May 26, 2017

Deirdre M. Daly, United States Attorney for the District of Connecticut, today announced that CAROL “CASEY” SMITH, 56, of Chester, Virginia, waived his right to be indicted and pleaded guilty yesterday before U.S. District Judge Stefan R. Underhill in Bridgeport to a federal charge related to his false certification of bridge inspection vehicles.

According to court documents and statements made in court, Under Bridge Inspection (“UBI”) vehicles are vehicles that contain a moveable boom with a platform. The vehicles are used to conduct inspections of bridges by positioning the vehicle on top of the bridge and, using the boom, lifting a platform carrying inspectors alongside or beneath a bridge deck. “Company A” rents or leases bridge access equipment, including UBI vehicles, to engineering companies and government agencies for use on bridge inspection and bridge maintenance projects. Company A’s UBI vehicles travel on interstate highways to job locations throughout the U.S. Company A has several locations, including one in Connecticut.

SMITH was the president and chief surveyor for Virginia-based Martin Enterprizes, Inc. (“MEI”). Between January 2012 and January 2015, SMITH falsely represented that he, as the chief surveyor for MEI, examined the UBI vehicles in Company A’s fleet on an annual basis. During that time, SMITH created 165 Certificates of Unit Text/Examination of Material Handling Device (the “Certificate of Inspection”) for UBI vehicles in Company A’s fleet. As part of the Certificate of Inspection, SMITH verified that he personally examined the specified UBI vehicle and that the UBI vehicle met federal requirements. SMITH also issued 165 annual stickers representing that he had inspected the UBI Vehicles, and he knew that an employee or employees of Company A would affix the stickers to the UBI vehicles, and that those UBI vehicles would be driven on interstate highways and used on jobs throughout the U.S., including Connecticut.

Between 2012 and 2015, in exchange for the Certificates of Inspection for the UBI vehicles, as well as other vehicles in its fleet, Company A paid SMITH a total of $76,400.

SMITH pleaded guilty to one count of making a false statement, which carries a maximum term of imprisonment of five years. A sentencing date is not scheduled.

This matter is being investigated by the U.S. Department of Transportation – Office of Inspector General and the U.S. Department of Labor – Office of Inspector General. The case is being prosecuted by Assistant U.S. Attorney Nancy V. Gifford.

Medicare Advantage Organization & Former COO to Pay $32.5 Million

Tuesday, May 30, 2017

Freedom Health Inc., a Tampa, Florida-based provider of managed care services, and its related corporate entities (collectively “Freedom Health”), agreed to pay $31,695,593 to resolve allegations that they violated the False Claims Act by engaging in illegal schemes to maximize their payment from the government in connection with their Medicare Advantage plans, the Justice Department announced today. In addition, the former Chief Operating Officer (COO) of Freedom Health Siddhartha Pagidipati, has agreed to pay $750,000 to resolve his alleged role in one of these schemes.

“When entering into agreements with managed care providers, the government requests information from those providers to ensure that patients are afforded the appropriate level of care,” said Acting Assistant Attorney General Chad A. Readler of the Justice Department’s Civil Division. “Today’s result sends a clear message to the managed care industry that the United States will hold managed care plan providers responsible when they fail to provide truthful information.”

The government alleged that Freedom Health submitted or caused others to submit unsupported diagnosis codes to CMS, which resulted in inflated reimbursements from 2008 to 2013 in connection with two of their Medicare Advantage plans operating in Florida. It also alleged that Freedom Health made material misrepresentations to CMS regarding the scope and content of its network of providers (physicians, specialists and hospitals) in its application to CMS in 2008 to expand in 2009 into new counties in Florida and in other states. The government’s settlement with Mr. Pagidipati resolves his alleged role in this latter scheme.

“Medicare Advantage plans play an increasingly important role in our nation’s health care market,” said Acting U.S. Attorney Stephen Muldrow. “This settlement underscores our Office’s commitment to civil health care fraud enforcement.”

“Medicare Advantage insurers must play by the rules and provide Medicare with accurate information about their provider networks and their patients’ health,” said Chief Counsel to the Inspector General Gregory Demske of the Department of Health and Human Services Office of Inspector General (HHS-OIG). “OIG will investigate and hold managed care organizations accountable for fraud. Moving forward, the innovative CIA reduces the risks to patients and taxpayers by focusing on compliance issues unique to Medicare Advantage plans.”

The allegations resolved by these settlements were brought in a lawsuit under the qui tam, or whistleblower, provisions of the Federal False Claims Act and the Florida False Claims Act. These statutes permit private parties to sue on behalf of the government for false claims and to receive a share of any recovery. The whistleblower in this action is Darren D. Sewell, who was a former employee of Freedom Health. The whistleblower’s share in this case has not yet been determined.

The corporate entities related to Freedom and which were part of today’s settlements are: Optimum HealthCare Inc., America’s 1st Choice Holdings of Florida LLC, Liberty Acquisition Group LLC, Health Management Services of USA LLC, Global TPA LLC, America’s 1st Choice Holdings of North Carolina LLC, America’s 1st Choice Holdings of South Carolina LLC, America’s 1st Choice Insurance Company of North Carolina Inc. and America’s 1st Choice Health Plans Inc.

Today’s settlements were the result of a coordinated effort by the Civil Division’s Commercial Litigation Branch, The U.S. Attorneys’ Office for the Middle District of Florida, HHS-OIG and the Florida Office of the Attorney General.

The claims resolved by the settlements are allegations only, and there has been no determination of liability. The case is captioned United States ex rel. Sewell v. Freedom Health, Inc., et al., Case No. 8:09-cv-1625 (M.D. Fla.).

Department of Energy OIG Enforcement under a Trump Administration

The United States Department of Energy (DOE) is a Cabinet-level department of the United States Government. Its responsibilities include the nation’s nuclear weapons program, nuclear reactor production for the United States Navyenergy conservation, energy-related research, radioactive waste disposal, and domestic energy production. It also directs research in genomics; the Human Genome Project originated in an iniative between DOE, NIH and international collaborators.  DOE sponsors more research in the physical sciences than any other U.S. federal agency, the majority of which is conducted through its system of National Laboratories.

Former Governor of Texas Rick Perry has been nominated as the next Secretary of Energy, and a vote is anticipated in the next few weeks.  April Stephenson currently serves as Acting Inspector General United States Secretary of Energy and will continue to head the department,  unless Secretary Perry makes a change. As a practical matter, DOE is unlikely to get a permanent Inspector General installed for many months. This means that its roughly 70 investigative agents in roughly 12 US cities will engage in enforcement that is somewhat skewed by perceptions about what a future Secretary of Energy will want.  For these reasons, I would project that investigative agents will believe they will ultimately receive more overhead support for investigations developed now.

Based on basic familiarity with DOE contracts and DOE-OIG investigative activity in the past as well as reasonable assumptions about how agents will interpret statements made by Trump Administration officials, I see three primary areas where agents will likely focus current efforts to develop cases:

1) Clean-up Sites.

Clean-up sites are viewed as cash cows with poor oversight.  I have lost track of how many there are, but there are  more than half a dozen prime ones including Hanford, Idaho Falls and Savanah River.  The Hanford site is an example of a site that has had longstanding troubles.  CH2MHill took a hit back in 2013 for an $18.5 million qui tam and, just recently, at the same site, BNI and URS agreed to  pay $125 Million for false claims regarding deficient nuclear quality procurements and improper payments to lobby Congress.  Internal conjecture is that there are more false claims being made at these and at other clean-up sites and it would behoove any companies involved at these sites to brush up on compliance and internally investigate around vulnerabilities or weaknesses.

2) Management and Operational (M&O) Contracts

Management Operations Contractors, whether deserved or not, are a source of frustration to enforcers.  These are huge, large dollar volume contracts that are viewed by enforcers as having poor oversight.  Other sources of frustration is that enforcers believe that they have no visibility with indirect contractors.  This feeling is even generally held in regard to direct contractors where transparency is lacking and contractors are perceived as foot dragging.  Because of lack of appetite in some US Attorney’s Offices for these complex investigations, there was less support in the past few years than perhaps there could have been, but I believe this will begin to change as the Trump Administrations enforcement priorities becomes more clear.

3) Green Grants

Although these are smaller dollar volume contracts, legal theories are easier to fashion around bite-sized grants and the story around each is usually more accessible to prosecutors and potential juries.  There is lingering resentment that politics adversely affected investigations that adversely impacted potential prosecutions (see Solyndra as an often cited example in the opinion of some) and there is a view among enforcers that investigations involving more than $2 billion in green grants and associated loans guaranteed by the government were never pursued appropriately.

* * * * * Here for the Rest of the Story * * * * * 

 

Latest GrantFraud.Com post involves a $200 million credit card fraud scheme

Bradford L. Geyer is reading enforcement agency tea leaves and he is seeing signs of enhanced enforcement involving grant fraud and procurement fraud at grantfraud.com.  His latest note regarding an extensive credit card fraud scheme can be found here.