Grant-Fraud Guilty Plea Underscores Potential Civil and Administrative Liability for Recipients of Federal Funds

For most individuals and organizations, it does not get much worse than the threat of a criminal conviction.  But for recipients of Federal funds—whether providers, grantees, or contractors—a federal criminal conviction is not necessarily the last straw.  In addition to consequences like debarment or program exclusion, a unique “statutory estoppel” provision can make it exceptionally difficult to defend against follow-on civil False Claims Act liability arising from the same alleged misconduct.