On August 8, 2024, the U.S. Attorney’s Office for the Central District of California announced a $6.3 million False Claims Act settlement with West Coast Dental Administrative Services LLC (formerly West Coast Dental Services Inc.) and its founders and former owners due to seven improper second-draw Paycheck Protection Program loans received by West Coast Dental and affiliated dental offices. Continue Reading California Dental Offices Settle FCA Allegations Regarding Second-Draw PPP Loans for $6.3M
Jason Crawford
When facing government investigations or high stakes litigation, clients trust Jason Crawford to evaluate allegations, identify risks, and formulate strategies to achieve the appropriate resolution. Jason advises and advocates for government contractors and companies from regulated industries in matters involving civil, criminal, and administrative enforcement, with a particular focus on the False Claims Act (FCA).
As a litigator, Jason has defended government contractors, drug manufacturers, grant recipients, health care companies, importers, and construction companies sued under the FCA by whistleblowers and the Department of Justice (DOJ) in federal courts throughout the country. He also helps clients conduct complex internal investigations and respond strategically to Office of Inspectors General inquiries, grand jury investigations, search warrants, and civil investigative demands.
Jason previously served as a DOJ Trial Attorney in the Civil Division, Fraud Section where he investigated and litigated FCA cases involving government contractors, importers, and health care companies. He also previously worked with the U.S. Attorney’s Office for the District of Columbia where he prosecuted federal criminal cases.
A recognized thought leader on FCA developments, Jason has written and presented extensively on the fraud statute, and he is a co-host of the Let’s Talk FCA podcast.
FCA Complaint Based on PPP Information Pulled from PandemicOversight.gov Website Barred
On August 5, 2024, in United States ex rel. Relator LLC v. Howard D. Kootstra and Golden Empire Mortgage, Inc., Case No. 1:22-cv-00924-TLN-CDB (E.D. Cal.), the District Court for the Eastern District of California granted a motion to dismiss allegations that a mortgage lender made false or fraudulent statements on its Paycheck Protection Program (PPP) application in violation of the False Claims Act where the relator could not overcome the FCA’s public disclosure bar.Continue Reading FCA Complaint Based on PPP Information Pulled from PandemicOversight.gov Website Barred
Let’s Talk FCA
Criminal Investigations and the False Claims Act
In this episode, Steve Byers, Jason Crawford, and Agustin Orozco discuss the intersection between False Claims Act investigations and parallel criminal proceedings. “Let’s Talk FCA” is Crowell & Moring’s podcast covering the latest developments with the False Claims Act.
Listen: Crowell.com | PodBean | SoundCloud | Apple
Let’s Talk FCA
Cost Accounting and the False Claims Act
In this episode, Jason Crawford, Agustin Orozco, and Erin Rankin look back at one of the more noteworthy settlements of 2023—the $377M settlement by Booz Allen Hamilton to resolve allegations arising out of the company’s purported non-compliance with Cost Accounting Standards. “Let’s Talk FCA” is Crowell & Moring’s…
501(c)(4) HOA to Pay Over $2M to Resolve FCA Allegations in Connection with PPP Loan
The San Diego Union-Tribune reports that a homeowners association (HOA) in California has reached an agreement with the Department of Justice (DOJ) to resolve allegations that the HOA obtained approximately $1.5 million in loans through the Paycheck Protection Program (PPP) that the HOA was not entitled to receive due to its status as a 501(c)(4) organization. The HOA reportedly will pay $2,037,451 to resolve the allegations. Of that amount, $244,494 will go to Wade Riner—the relator who initiated the action by filing a complaint under seal pursuant to the qui tam provisions of the False Claims Act (FCA). According to the Tribune’s reporting, Riner has filed dozens of similar FCA suits across the country.Continue Reading 501(c)(4) HOA to Pay Over $2M to Resolve FCA Allegations in Connection with PPP Loan
Let’s Talk FCA
Civil-Cyber Fraud Initiative
In this episode, Jason Crawford, Nkechi Kanu, and Agustin Orozco discuss a recent settlement that underscores the DOJ’s increased use of the False Claims Act to enforce noncompliance with cybersecurity requirements. “Let’s Talk FCA” is Crowell & Moring’s podcast covering the latest developments with the False Claims Act.
Listen: Crowell.com |…
Affiliation Renders PPP Borrower Not Small for its $6.28M PPP Loan, Resulting in a $9M FCA Settlement
On October 11, 2023, the Department of Justice announced a $9 million settlement with Victory Automotive Group Inc. (VAG) to resolve allegations that it violated the False Claims Act (FCA) by knowingly providing false information in support of its Paycheck Protection Program (PPP) loan. This settlement is one of the larger ones to date related to receipt of a PPP loan and one of the first in which affiliation rendered a PPP borrower other than small.Continue Reading Affiliation Renders PPP Borrower Not Small for its $6.28M PPP Loan, Resulting in a $9M FCA Settlement
Civil Cyber-Fraud Settlement Highlights Potential for Cooperation Credit
A False Claims Act (FCA) settlement recently announced by the U.S. Department of Justice stands at the intersection of two evolving trends: DOJ’s increasing focus on cybersecurity lapses by government contractors as part of its Civil Cyber-Fraud Initiative, and DOJ policies incentivizing corporations to voluntarily self-disclose violations of federal law.
On September 5, 2023, DOJ announced a $4 million settlement with Verizon Business Network Services LLC (Verizon) addressing allegations that Verizon violated the FCA because certain telecommunications services it provided to federal agencies under its General Services Administration (GSA) contracts did not comply with applicable cybersecurity requirements, namely the Office of Management and Budget’s Trusted Internet Connections (TIC) initiative. DOJ specifically alleged that Verizon’s Managed Trusted Internet Protocol Service (MTIPS)—an information technology service that allows federal agencies to securely connect to public internet and external networks—did not comply with three security controls in the Department of Homeland Security’s TIC Reference Architecture Document, including a control that required the use of FIPS 140-2 validated cryptography. The Verizon settlement represents the latest example of DOJ’s continued focus on cybersecurity cases, a trend that we believe will only continue to escalate going forward.Continue Reading Civil Cyber-Fraud Settlement Highlights Potential for Cooperation Credit
Let’s Talk FCA: Pandemic Relief Fraud
In this episode, Jason Crawford, Olivia Lynch, and Agustin Orozco discuss government investigations and enforcement trends regarding pandemic relief fraud. “Let’s Talk FCA” is Crowell & Moring’s podcast covering the latest developments with the False Claims Act.
Listen: Crowell.com | PodBean | SoundCloud | Apple Podcasts
No End in Sight: The Long Tail of COVID Relief Fraud Enforcement
Although the COVID-19 public health declaration officially ended in May, government investigations of pandemic relief fraud are from over. As observed in a recent report by the Small Business Administration Office of Inspector General, investigations will likely ensue for years to come in light of Congress’s decision to extend the statute of limitations to ten…