Legal Issues Related to the Program Fraud Civil Remedies Act of 1986

Issues were addressed regarding the implementation of the Program Fraud Civil Remedies Act of 1986. It was determined that the: (1) act's $150,000 limit was jurisdictional and agencies could not apply the act's administrative remedies to false claim cases involving amounts greater than $150,000; (2) act's provision that investigating officials could not supervise reviewing officials did not prohibit a close working relationship; and (3) Department of Housing and Urban Development's, Department of Health and Human Services', and the Air Force's arrangements for implementing the act were consistent with provisions requiring the separation of prosecutorial and judicial functions.