Promoting FCA Cooperation Guidance, DOJ Dangles Discretion to Make FCA Allegations Go POOF!

The recent rollout of DOJ's False Claims Act Cooperation Guidance left many practitioners scratching their heads about how it really changed the landscape on cooperation since, as we previously blogged: the policy provides "much discussion of what constitutes cooperation," while saying little "of the benefit of the bargain"—particularly for self-disclosure.