At the hearing, David W. Ogden, a partner with WilmerHale in Washington, D.C., who was testifying on behalf of the U.S. Chamber of Commerce’s Institute for Legal Reform, said companies with certified compliance programs that self report violations should face reduced penalties under the FCA.
Mr. Ogden, who was joined at the hearing by Sen. Chuck Grassley (R-Iowa), also said the FCA should be revised to incentivize organizations to self report violations by removing the threat of future qui tam, or whistle-blower, cases based on the same issue.
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