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Sarah Bartle

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DOJ Issues New Guidance on the Evaluation of Corporate Compliance Programs

Posted in Ethics & Compliance
On February 8, 2017, the Department of Justice Fraud Section posted a new guidance document on its website entitled, “Evaluation of Corporate Compliance Programs”  (“Compliance Guidance”).  This Compliance Guidance, comprised of a number of topics and questions, comes a little over a year after the Fraud Section hired Hui Chen as its resident compliance expert. … Continue Reading

For Whom Does the Appeal Clock Toll? Vitiation vs. Finality

Posted in Legal Developments
In Guardian Angels Med. Serv. Dogs Inc. v. U.S. (Jan. 8, 2016), the Federal Circuit held that a CO’s request to evaluate additional information after a default termination “vitiated the finality” of the termination and reset the 12-month appeal clock, even though the CO neither received new information nor spent any time reconsidering her decision.… Continue Reading