On August 1, 2024, the Department of Justice (“DOJ”) finally released its much anticipated Corporate Whistleblower Awards Pilot Program, yet another DOJ program intended to incentivize the prompt investigation and disclosure of misconduct. The pilot program offers significant financial rewards to individuals for reporting financial fraud, bribery, and healthcare fraud engaged in by corporations. First announced in March of this year, the program continues to ramp up the pressure on companies to quickly self-disclose allegations of misconduct—perhaps even before corporations are able to determine if disclosure is necessary.
The program may well result in a significant increase in whistleblower reports. Corporations would be well advised to review their investigation protocols to ensure reported misconduct can be expeditiously investigated. Fortunately, the new program does continue to allow corporations to receive traditional self-disclosure benefits—even if an employee has submitted a whistleblower report—if the company reports the same conduct to the DOJ within 120 days and DOJ has not contacted the company first.
As a result, when allegations of misconduct come to light, corporations must now be ready to quickly assess the claims, deploy investigators, and decide whether to disclose conduct to the DOJ before the benefit of self-disclosure is lost. After all, employees will be incentivized to report the conduct to DOJ and the 120 days clock may already...
A Houston-area neurosurgeon will pay $2,095,946 to resolve allegations he submitted false claims for the placement of electro-acupuncture devices, the U.S. Department of Justice announced. Dr. Raje...