Shift in Policy on Guidance Documents Suggests Change in DOJ Attitude Towards FCA Enforcement
March 15, 2018
Within the past few months, the Department of Justice (the “DOJ”) has released a series of memos that indicate a shift in its policy related to the treatment of agency guidance documents.
This memorandum seeks to explain this policy shift and analyze its potential impact in the area of False Claims Act (“FCA”) enforcement.
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