Preparing for the Coming Onslaught of Government Investigations and Audits of COVID-19 Relief Funds and Contracting—Part III
This is the third in a series of articles concerning the audits and investigations related to the contracts and grants awarded, and relief funds provided, in response to the COVID-19 pandemic. This article addresses how to know whether you or your company is under investigation or review or being considered for investigation or review.
In our previous articles, we discussed the multiple government enforcers and regulators charged with authority to oversee the application, eligibility, and use of COVID-19 relief funds. This article addresses how to know whether you or your company is under investigation or review or being considered for same. Sometimes it is obvious—for example, when the Federal Bureau of Investigation (“FBI”) along with other agencies raid your offices. Other times, the signs are subtle.
The federal government has an arsenal of tools it uses to gather information for investigations and audits. These tools are not new and are not specific to COVID-19 relief funds. However, some of the “new” entities created by COVID-19 relief legislation (e.g., the Special Inspector General for Pandemic Recovery (“SIGPR”)), as well as the coordination of agency inspectors general on the Pandemic Response Accountability Committee (“PRAC”)), can use those same old tools to hone in on recipients of COVID-19-related funding.
Below are some practical tips to understand whether you are being investigated based upon investigative tools used by the government.
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“Preparing for the Coming Onslaught of Government Investigations and Audits of COVID-19 Relief Funds and Contracting—Part III,” by Merle M. DeLancey Jr., Craig Stetson*, and Jennifer A. Short was published in the August 2021 issue of Pratt’s Government Contracting Law Report (Vol. 7, No. 8), an A.S. Pratt Publication, LexisNexis. Reprinted with permission.
* Craig Stetson is a partner with Capital Edge Consulting where he focuses on assisting contractors interpret and apply the accounting and regulatory compliance requirements associated with federal government contracts.