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B-239597 January 23, 1991

B-239597: Jan 23, 1991

Memorandum examines several agencies' implementation of the Program Fraud Civil Remedies Act of 1986 and concludes that their arrangements are consistent with the provisions of the act and the Administrative Procedure Act requiring separation of prosecutorial and judicial functions in administrative proceedings. The benefits that have been achieved. Whether additional remedies are needed to reduce...

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

B-239597: Jan 23, 1991

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 prohib...

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