False Claims Act: A Primer and Guide for Research Organizations

This course provides an introduction to the False Claims Act ideally suited for faculty, researchers, and staff at research organizations.

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About this Course

Organizations, as well as individual researchers, may face stiff penalties under the False Claims Act (FCA) for problems in grant applications and reporting. As awardees of federal funds and the entities bound to comply with grant terms and conditions, individuals and organizations need to understand how the FCA works and what risks it poses.

This course provides critical training to individuals in research organizations on the FCA and Civil Monetary Penalties Law (CMPL). It begins with the purpose of the laws, explains when liability attaches, discusses the consequences and potential penalties if a violation occurs, and provides examples of recent FCA settlements between research organizations and the U.S. federal government.

The course also identifies common risk factors that may lead to FCA and Civil Monetary Penalty (CMP) liability and recommends ways to mitigate those risks at an organization. The last module in this course provides information on managing and resolving FCA and CMP cases, the pros and cons of voluntary self-disclosures, and the process for responding to government requests and subpoenas, including working with counsel.

This course was written by Keri Godin, MS, Valerie H. Bonham, Esq, and S. Susan Zhu, Esq and peer reviewed by experts.

Language Availability: English

Suggested Audiences: Institutional Officials, Principal Investigators, Research Administrators, Research faculty, Students

Organizational Subscription Price: $675 per year/per site for government and non-profit organizations; $750 per year/per site for for-profit organizations
Independent Learner Price: $99 per person

Demo Instructions

Course Content

Introduction to the Federal False Claims Act

This module introduces the False Claims Act (FCA), including the scope of FCA liability, the role of “whistleblower” or “qui tam relator,” and penalties available under the act. Learners will also review civil monetary penalty (CMP) liability and the penalties available under the Civil Monetary Penalties Law (CMPL). The module concludes with a discussion on the applicability of both FCA and CMPL to federally funded research.

Recommended Use: Required
ID (Language): 20026 (English)
Author(s): Keri Godin, MS - Brown University; Valerie H. Bonham, Esq. - Ropes and Gray, LLP; S. Susan Zhu, Esq - Ropes and Gray, LLP

Recognizing and Mitigating FCA Risks in Research

The threat of False Claims Act (FCA) liability or costs to defend FCA claims has compelled some academic and clinical research organizations to develop more robust internal controls and dedicate resources to building effective compliance and research integrity programs. This module explores risk indicators for potential FCA and civil monetary penalty vulnerabilities, including areas of potential risk for research organizations accepting federal funds. The module concludes with practical ways to mitigate risk.

Recommended Use: Required
ID (Language): 20027 (English)
Author(s): Keri Godin, MS - Brown University; Valerie H. Bonham, Esq - Ropes and Gray, LLP; S. Susan Zhu, Esq - Ropes and Gray, LLP

Managing and Resolving FCA and CMP Cases

Even organizations that have implemented appropriate safeguards are not immune to the emerging risk of False Claims Act (FCA) liability and civil monetary penalty (CMP) vulnerabilities. They must establish and, if warranted, implement a plan for self-reporting when confronted with activities involving federal research dollars that may constitute fraud. Organizations must be prepared to respond when an FCA or CMP allegation is brought to light, either through self-discovery or an externally-initiated investigation. This module discusses potential benefits and drawbacks of self-disclosure, practical considerations for responding to government requests, and the role of counsel in helping organizations navigate FCA and CMP actions.

Recommended Use: Required
ID (Language): 20028 (English)
Author(s): Keri Godin, MS - Brown University; Valerie H. Bonham, Esq - Ropes and Gray, LLP; S. Susan Zhu, Esq - Ropes and Gray, LLP


Who should take the False Claims Act: A Primer and Guide for Research Organizations course?

The suggested audiences are research faculty, research administrators, institutional officials, principal investigators, and students.

Why should an organization subscribe to this course?

Organizational subscriptions provide access to an organization's affiliated members. This allows organizations to meet the training needs of learners who should have knowledge of the False Claims Act and Civil Monetary Penalties Law.

Why should an independent learner consider taking this course?

Independent learners can take this course to understand the False Claims Act (FCA) and Civil Monetary Penalties Law (CMPL). The course covers important topics related to FCA and CMPL.

How does the course work?

The course consists of three self-contained, self-paced modules. Each module includes an in-depth discussion along with case studies, practical examples, supplemental resources, and a quiz.

How long will the course take a learner to complete?

Although completion time will vary by learner, each module takes about 25-30 minutes to complete. The modules are designed so that learners can complete them in one sitting or in multiple sittings, and there is no time limit for any of the activities.

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