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Department of Labor Institutes New Pilot Program to Expedite Processing of Discretionary Suspensions and Debarments

Client Alert | 1 min read | 04.04.19

On April 2, the Department of Labor (DOL) announced a new pilot program for discretionary suspensions and debarments in an effort to decrease DOL’s processing time of these actions “from months to days.” As part of the program, DOL’s Office of Inspector General (OIG) will include in its referrals to the Office of the Assistant Secretary for Administration and Management (OASAM) information based on indictments or convictions, with the hope that such information will allow OASAM to process these actions more quickly. Because of the unique nature of DOL debarments – which are largely imposed as a collateral consequence of labor violations – the pilot program increases risk to government contractors under scrutiny by DOL and its components/programs. This development emphasizes the importance of hiring counsel with capabilities to address the full spectrum of risks, including a proactive approach to suspension and debarment defense. 

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Client Alert | 8 min read | 03.05.26

Fifth Circuit Decision in Health Care Fraud Case Highlights Importance of Careful Drafting in Civil RICO Complaints

A recent decision by the United States Court of Appeals for the Fifth Circuit, Farmers Texas County Mutual Insurance Co. v. 1st Choice Accident & Injury, LLC, No. 24-20275 (5th Cir. Feb. 24, 2026), offers important lessons for health care payors and other potential plaintiffs considering civil claims under the federal Racketeer Influenced and Corrupt Organizations Act (RICO). Although the Fifth Circuit’s decision focused on a procedural issue, the underlying case turned on a fundamental pleading failure: the plaintiff insurers did not adequately describe the fraudulent network they were suing as a RICO “enterprise.” The result was dismissal of a $14 million fraud case....