BC Advantage - 2022 Issue 8
Self-Audits
Self-audits are critical. They demonstrate compliance, or at least a "good-faith effort" to be compliant; they minimize refunds of overpayments to "actuals" and also mitigate the potential for a multiple being added. Most importantly, they prevent an auditor, agent, or prosecutor from making an allegation of malfeasants and/or, in a worse case, a reverse False Claims Act (under the Fraud Enhancement and Recovery Act (FERA) of 2009, the Act expanded liability under the False Claims Act. Prior to the FCA being amended, a relator had to prove that a false statement or record was created. Under the 2009 amendment...
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