Whistleblower Paid $9,243,251 For Exposing False Claims Scheme

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On June 7, 2012, the Department of Justice reported that it had recovered $34,234,263 from Orthofix Inc., a Texas-based manufacturer of medical devices, to settle allegations under the civil False Claims Act relating to the company’s sale of bone growth stimulator devices. The Justice Department awarded whistleblower Jeffrey Bierman $9,243,251 for his contribution in providing the U.S. Government with insider information on the false claims scheme. The Justice Department also announced that the company had agreed to plead guilty to a felony of obstruction of a federal audit and to pay a $7,765,737 criminal fine.

The whistleblower suit alleged that the “company improperly waived patient co-payments, thus misstating their true cost and resulting in overpayments by federal programs; paid kickbacks to physicians and their staffs in the form of “fitter fees,” referral fees and other comparable fees, to induce the use of Orthofix products; caused the submission of falsified certificates of medical necessity; and failed to advise patients of their right to rent rather than purchase Orthofix products.”

Stuart F. Delery, Acting Assistant Attorney General for the Civil Division stated that “the Justice Department has longstanding concerns about kickbacks and the routine waiver of co-payments, because they can impose significant costs on federal health programs that are not medically justified.” “The resolution of this matter yielded a substantial recovery for taxpayers, and should deter other companies from engaging in such conduct in the future.”

The Justice Department stated that the company’s criminal guilty plea involved its failure to disclose information concerning its practices regarding certificates of medical necessity to a Medicare contractor where five individual Orthofix employees previously plead guilty to criminal charges in connection with this matter. U.S. Attorney for the District of Massachusetts,Carmen M. Ortiz, stated that “this resolution, and the entire investigation, which has involved prosecution of a number of individuals, including a high level executive, demonstrates the government’s unflagging commitment to prosecuting corporate and individual medical device fraud, and particularly to protecting Medicare from those who prey on it by fraudulent means.”

Susan J. Waddell, Special Agent in Charge of the Office of Inspector General of the U.S. Department of Health and Human Services New England region stated that “criminals intent on placing profits from federal health programs over and above compliance should expect to tangle with authorities” and that “Orthofix blatantly ordered sales staff to disregard Medicare rules, and conveniently looked away when medical records were altered and even forged.”

The False Claims Act allows private citizens to act as whistleblowers and sue on behalf of the government and share in the amounts the government recovers through legal action.The False Claims Act allows the government to recover treble damages and $5,500 to $11,000 for each false or fraudulent claim filed. The whistleblower in this case was paid approximately 27% of the proceeds from the government settlement.Whistleblower rewards typically range from between 15-30% for claims brought under the False Claims Act.

Young Law Group, P.C., Attorneys-at-Law, represents whistleblowers nationwide. For a free confidential consultation, please call Eric L. Young, Esquire at 1-800-590-4116 or email to eyoung@young-lawgroup.com.

SOURCE: http://www.justice.gov/opa/pr/2012/June/12-civ-724.html

Doctors receive $130k for Exposing Illegal Medicare Kickback Scheme

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Medicare Kickback Scheme

On August 14, 2012, the Department of Justice reported that it had recovered $650,000 and settled claims against Dr. Jack L. Baker, a prominent Houston radiologist, for allegations that he violated the False Claims Act, the Anti-Kickback Statute, the Stark Act and the Texas Medicaid Fraud Prevention Act. The Justice Department awarded two doctors, Drs. Philip Blum and David Spinks, $130,000 for their contribution in providing the U.S. Government with insider information on Dr. Baker’s illegal payment compensation scheme to doctors to induce them to refer patients to Fairmont Diagnostic Center and Open MRI Inc.

The Stark Statute and the Anti Kickback Statute disallows Medicare providers from billing Medicare for referrals from doctors with whom the providers have a financial relationship, unless that relationship falls within certain exceptions. United States Attorney Kenneth Magidson stated that “improper financial relationships between health care providers and their referral sources can corrupt a physician’s judgment about the patient’s true healthcare needs” and such arrangement “incentivize physicians to make referrals for unnecessary tests.”

In this case, Dr. Baker had entered into improper financial relationships with approximately 17 physicians to induce them to refer patients to Fairmont Diagnostic Center for a wide variety of imaging studies. The prohibited financial relationships included, sham personal services contracts (medical directorships) and contracts to pay the salaries of employees in physicians’ offices.

The False Claims Act allows private citizens to sue on behalf of the government and share in any amounts recovered through legal action.For their work, Drs. Blum and Spinks received 20% of the proceeds of the settlement. Dr. Baker also agreed in the settlement to a voluntary suspension from the Medicare and Medicaid programs for a period of six years and will not be allowed to bill these programs for treating Medicare and Medicaid beneficiaries.

Young Law Group, P.C., Attorneys-at-Law, represents whistleblowers nationwide. For a free confidential consultation, please call Eric L. Young, Esquire at 1-800-590-4116 or contact one of our other False Claims lawyers.

SOURCE: http://www.justice.gov/usao/txs/1News/Releases/2012%20August/120814%20Baker.html

First SEC Whistleblower Paid $50,000 For Exposing Securities Fraud

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On August 12, 2012, the Securities and Exchange Commission reported that it had recovered $150,000 thousand so far out of a Court order $1 million in sanctions against the perpetrators of securities fraud scheme.  The Securities and Exchange Commission awarded the whistleblower, who wishes to remain anonymous, $50,000 for his/her contribution in providing the U.S. Government with provided documents and other significant information that allowed the SEC to investigate, move quickly, and prevent the fraud from ensnaring other victims.  Any additional amount collected will increase the payments to the whistleblower.

SEC Chairman Mary L. Schapiro, stated that “[w]e’re seeing high-quality tips that are saving our investigators substantial time and resources” and that “[t]he whistleblower program is already becoming a success.”  Robert Khuzami, Director of the SEC’s Division of Enforcement stated that “[h]ad this whistleblower not helped to uncover the full dimensions of the scheme, it is very likely that many more investors would have been victimized.”  He also said that “[t]his whistleblower provided the exact kind of information and cooperation we were hoping the whistleblower program would attract.”  The SEC stated they get about 8 tips per day.

The Dodd-Frank Act allows the SEC to reward individuals who offer high-quality original information that leads to an SEC enforcement action in which more than $1 million in sanctions is ordered.  The whistleblower in this case was paid approximately 30% of the amount the government recovered.  The SEC issues rewards between 10% and 30% of the money collected.  “The law specifies that the SEC cannot disclose any information, including information the whistleblower provided to the SEC, which could reasonably be expected to directly or indirectly reveal a whistleblower’s identity.”

SOURCE: http://www.sec.gov/news/press/2012/2012-162.htm

For additional information about the SEC whistleblower program, please contact one of our SEC whistleblower lawyers.

IRS TAX FRAUD WHISTLEBLOWER AWARDED $104 MILLION

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Philadelphia, PA September 12, 2012 – Whistleblower Attorneys for Bradley Birkenfeld, a jailed former Swiss banker, announced that the Internal Revenue Service (IRS) will award him a $104 Million as a tax whistleblower reward for detailed information he turned over to the U.S. government concerning the detailed inner workings of Swiss bank UBS’s secretive private wealth management division and illegal offshore banking scheme.

It is believed that this reward – the largest ever single reward paid to an IRS tax whistleblower – is the 4th reward paid to date since the IRS Whistleblower Program went into effect in 2006.The first IRS whistleblower award of $4.5 million was issued to an anonymous accountant in April 2011 after he exposed that his employer, a Fortune 500 financial services firm, was skimping on taxes.Since that time, the IRS has been under intense scrutiny due to the apparent lack of progress with respect to its handling of IRS whistleblower claims including scathing reports by the Government Accountability Office and the Treasury Inspector General for Tax Administration.

Senator Charles Grassley, the Iowa Republican who spearheaded the legislation that led to the creation of the IRS Whistleblower Office and who also has been vocal about his unhappiness with regard to the IRS’s slow approach to whistleblower tips, declared today, “This case provides evidence about how the whistle-blower program can be effective because the IRS is saying its work against this kind of tax fraud would not have been possible without the whistle-blower.”

The Birkenfeld case is an indication by the IRS that it takes whistleblower claims seriously while encouraging others to report fraudulent activity.Attorney Eric L. Young, of the nationally renowned Whistleblower Attorney Firm, Young Law Group, who represented the accountant who received the first ever IRS tax whistleblower award, congratulates Mr. Birkenfeld and his attorneys, “I know first-hand the challenges faced by people like Mr. Birkenfeld when stepping forward to report serious fraudulent activity.In this extreme case, Mr. Birkenfeld arguably paid the ultimate price – time in jail – after deciding to come forward.Blowing the whistle on corporate fraud and misconduct is not for the faint of heart and that is why the government pays rewards.It also underscores the importance of hiring experienced IRS whistleblower attorneys.My hat goes off to Mr. Birkenfeld and his attorneys who did a tremendous job in not only ensuring that UBS AG was held accountable for helping tax cheats, but in bringing attention to scope of efforts by wealthy U.S. citizens to evade taxes by way of off-shore bank accounts.”

Young Law Group (“YLG”) is a nationally renowned law firm specializing in the representation of whistleblowers and individuals in fraud and class action litigation. Our attorneys have litigated cases resulting in recoveries exceeding $2 Billion against corporate giants including Anheuser-Busch, Pfizer, Ikon, Cephalon, Johnson & Johnson, Fresenius, Merck, Aramark, and others.

To learn more about whistleblowing and how we can help protect your rights please complete our online form to the right or call us at 800-590-4116.

Update: Young Law Group is now operating as McEldrew Young. Links in the press release have been updated with our new website address.

IRS Whistleblowing Potential

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Trying to save money, the federal government is cutting funding for the IRS. The result may be a loss of revenues costing taxpayers untold billions. By the end of Fiscal Year 2010, $330 billion dollars in federal taxes will remain uncollected. In context, $330 billion dollars represents nearly 9 times the projected savings of the recently agreed upon budget. However, in the recent budget agreement, lawmakers decided that no additional funds would be used to hire new IRS agents.

Although there is evidence that for every dollar spent on enforcing the tax code the investment results in up to ten dollars of revenue for the government. Politicians, fearing to align themselves with the tax man, have shown reluctance in supporting funding for additional IRS agents.

The idea is particularly troublesome in that the federal deficit continues to mount and broader compliance of the already existing tax code would help relieve the burden of an exploding deficit. Egan Young’s recent case is a prime example of the need for a strong IRS. An anonymous Whistleblower client of Egan Young received the very first mandatory tax fraud reward under the 2006 IRS Whistleblower rules.

The program which had been in place since the end of 2006, had taken nearly five years to distribute its first mandatory reward. The IRS acting on the tip of the Whistleblower, and the advocacy of attorney Eric Young, netted in excess of $20 million in unpaid federal taxes. This recent case highlights the need for a strong IRS. $20 million from one case represents near 2/3 of the savings the federal government cut in its recent budget negotiations. The addition of IRS agents, resources for the whistleblower office, and increased investment in IRS infrastructure would be a nearly 10 to 1 investment in paying down the exploding federal deficit.

Fear of Political Pressure Influences IRS Resistance to Whistleblower Cases

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In recent years, whistleblower cases have proven to be essential to the battle against tax fraud in the United States. In 2006, Congress passed a provision that would allow citizens to file claims with the Internal Revenue Service (IRS) to recover lost tax revenue that had been fraudulently withheld. The Tax Court could intervene on behalf of a relator, or whistleblower, but only in reviewing the awarded damages. Since Congress only authorized the review of the award rather than the merit of the cases, many are turned down by the IRS. One example of the IRS’ resistance to pursing whistleblower cases is in William Prentice Cooper, III v. Commissioner, 136 T.C. No. 30 (June 20, 2011). The IRS declined the relator’s request to pursue a case because the agency believed it did not meet the criteria required for litigation. The IRS cannot be expected to take every whistleblower case that comes through the door, but in the current climate of fiscal uncertainty, it could be worth millions to the government to re-evaluate certain cases and subject them to closer scrutiny.

As noted by Finch McCranie, LLP, whistleblowers have recovered $97 million for the U.S. government WITHOUT the help of the Justice Department. That is more than the combined salaries of both the members of the United States Senate and House, according to Pat Burns of Taxpayers Against Fraud. This was done without the Justice Department because the government declined to pursue the cases, even when presented with meritorious information. If the IRS has the opportunity to recover tax funds for the government, which it is required to do, why is the agency passing on the opportunity to increase the chances of a successful lawsuit?

The Internal Revenue Service says in its mission statement that it seeks to ensure that citizens meet their tax responsibilities and enforce the laws that Congress passes to ensure fairness and integrity for all. As a result, the IRS is subject to the mercy of Congress, even though its responsibilities are supposed to be nonpolitical.

This political control over the IRS also showed itself when the agency caved to Republican pressure over private campaign donations as gifts.

As noted by Dan Froomkin of the Huffington Post, in this case Republican members of the Senate Budget Committee and the House Ways and Means Committee believed that the IRS was pursuing a liberal agenda by auditing the gifts of donors who have contributed to 501(c)(4)s. They tried to justify their argument by noting that the provision the IRS cited had not historically been enforced. Even if this is the case, it only highlighted the IRS’ failures in the past, but not the present. When Congress passes a law, all of its provisions must be enforced by the IRS. If the provision for declaring gift contributions was never intended to be enforced, then Congress should not have included it in the legislation.

The IRS will always be subject to the laws of Congress, and as a result, the business of politics will get in the way of the agency’s ability to effectively carry out its mission. With Republican donors traditionally holding interests in private companies and firms, they are more inclined to put pressure on the IRS to decline whistleblower cases, seeing as they have the potential to have an adverse effect on these companies. Is it right to allow fraud to continue and additional government revenue to be lost as a result of political interests? More attention should be given to whistleblower since they are not only privy to information that could expose illegal actions, but also they could bring in the additional tax revenue that would help this country combat the devastating fiscal crisis that we are inching closer and closer towards today.

Egan Young, Attorneys-at-Law, represents whistleblowers nationwide. For a free confidential consultation, please call Eric L. Young, Esquire at (215) 367-5151 or email to eyoung@eganyoung.com.

SEC Approves Whistleblower Rules

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The SEC has approved the rules regarding the submission of SEC whistleblower claims pursuant to the Dodd-Frank legislation that was passed last year.

As reported By David S. Hilzenrath, here, The SEC approved rules Wednesday that could make it highly lucrative for Wall Street whistleblowers and other corporate insiders to alert the agency to securities violations. The agency was acting at the behest of Congress and President Obama, who mandated the rewards last year in legislation responding to the mortgage meltdown.

Whistleblowers will be entitled to receive 10 percent to 30 percent of the money they help the SEC collect through enforcement actions. Corporations had lobbied intensely for rules that would impose constraints on whistleblowers. But a majority of SEC commissioners rejected pleas by business groups that, before going to the SEC, whistleblowers should be required to notify the companies they are accusing and give those companies a chance to address the allegations.

“For an agency with limited resources like the SEC, I believe it is critical to be able to leverage the resources of people who may have first-hand information about potential violations,” Schapiro said in her prepared text. “And, it is especially important to investors whose savings or retirement funds may hinge on our ability to stop an ongoing fraud or obtain hidden evidence,” Schapiro said. Schapiro, an independent, and two Democratic commissioners voted for the rules over the opposition of two Republican commissioners.Republican commissioner Kathleen Casey said the SEC was overestimating its ability to triage and manage complaints from tipsters while underestimating the extent to which the rules will undermine companies’ efforts to police themselves through internal compliance programs.

The rules can be read in entirety by clicking here.

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This is a victory for whistleblowers and investors alike.  If you have information concerning a violation of the SEC or the commodities market, contact an SEC whistleblower attorney at McEldrew Young today for a free CONFIDENTIAL consultation at 215-367-5151.

McKessy Named Head of SEC Whistleblower Office

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The Securities and Exchange Commission recently announced that Sean McKessy will oversee the new Whistleblower Office in the Division of Enforcement. The Office will consolidate existing resources to administer the whistleblower provisions called for by The Dodd-Frank Wall Street Reform and Consumer Protection Act.

In that role, Mr. McKessy will lead a program charged with working with whistleblowers, handling their tips and complaints, and helping the Commission determine the awards for individuals who provide the agency with information that leads to successful enforcement actions.

Mr. McKessy rejoins the SEC, where he was a Senior Counsel in the Division of Enforcement from 1997 to 2000. More recently, Mr. McKessy served as corporate secretary for both Altria Group, Inc. and AOL Inc., and as securities counsel for Caterpillar, Inc. In these roles, Mr. McKessy developed and supervised internal compliance and reporting programs related to the federal securities laws, served as corporate compliance officer, and coordinated the reporting of potential violations to boards of directors.

“Sean is uniquely positioned to oversee the Commission’s whistleblower program,” said Robert Khuzami, Director of the SEC’s Division of Enforcement. “The Enforcement Division and whistleblowers alike will greatly benefit from Sean’s first-hand experience in bringing enforcement cases, handling whistleblower complaints and understanding the workings of internal corporate compliance programs.”

Mr. McKessy said, “I am excited to return to public service and rejoin the dedicated staff of the Enforcement Division in this critical role. Whistleblowers often provide invaluable information that can help uncover securities fraud and protect investors.”

The Dodd-Frank Wall Street Reform and Consumer Protection Act requires the SEC whistleblower program to pay rewards to individuals who voluntarily provide the Commission with original information that leads to successful SEC enforcement actions and certain related actions. The Commission is in the process of developing rules that will guide the whistleblower program.

The SEC deferred plans to set up a whistleblower office in December in anticipation of a budget battle with congressional Republicans, most of whom opposed the law. The SEC stated that the office will “consolidate existing resources” to administer the new program.

The Obama administration’s fiscal 2012 budget plan calls for 43 new positions “to expand investigations of tips received from whistleblowers.”

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Brandon J. Lauria, Esquire, represents whistleblowers nationwide.  If you would like to speak with Mr. Lauria or one of our other SEC whistleblower attorneys, please email him directly at blauria@young-lawgroup.com or cal 215.367.5151 for a free consultation today.

Qui Tam and Big Oil, All Over Again

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When it comes to classic whistleblower cases, oil always comes to the surface.

The recurring saga, alleged mismanagement, and waste, of the federal Minerals Management Service (MMS) revealed the recurring nature of oil oversight: and the frustrating, often ignored, role of whistleblowers.

In 2007, what was viewed as a vital internal reform effort against MMS, the Kerr-McGee jury verdict of $7.6M, was dismissed by the trial court. It took an agonizing, long year, but a federal court of appeals reversed the dismissal, and resurrected the award.

Ironically, but not at all unusual for a qui tam, the government was entitled to share equally with the whistle blower, Bobby Maxwell (a former MMS auditor). Ironic, since Maxwell had discovered a series of underpayments by the exploration company to MMS. After reporting the apparent underpayments to her MMS superiors, Maxwell’s complaints were apparently “deep sixed.” Evidence at trial suggested the total of Kerr-McGee’s underpayments in licensing, royalties, fees, and penalties might exceed $30 million.

Though not an apologist for the  industry—let alone any certainty of avoiding the 2010 Gulf leak— there is little doubt many experts see oil as being…between  a rock and  hard place, when it comes to harsh realities. Oil, expensive in its location, often prohibitive in its extraction, represents the drilling of human potential…and human exploitation: Niger Delta, Prudhoe Bay, California. All are viewed as pristine and natural bounties: and areas ripe for billions in payments to greedy government bureaucrats. But few people suspected, when Maxwell became a reluctant whistleblower, that many employees at MMS/Denver might be as open to graft as international oil cartels.

It is also remarkable, perhaps, to consider the revelations attendant to the Maxwell case were essentially ignored. Only when the top blew off the Deepwater Horizon platform were many of the reports aired by Maxwell’s whistle blowing revealed: employees accepting gifts, and even suggestions of improper liaisons (Reported by the Denver Post 09/11/2008).

The costs of forcing these resolutions to individual qui tam actions are high, in terms of oil market efficiency, as well. Kerr-McGee—after its losses in court—was absorbed by massive Anadarko Petroleum. Yet the problem goes much deeper than costs of whistle blowing. A study by the non-profit Common Dreams reported that MMS has cited thousands of oil spills in the last decade.

Source:
http://www.commondreams.org/headline/2010/06/11-2.

Whistleblowing Across the Pond

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As one of our writers recently crossed the Atlantic to find out more about governance in Europe, she coincidentally came across this poster. Occupying ad space in numerous places on one of London’s major streets, the poster promotes blowing the whistle on housing fraud. While blowing the whistle on housing fraud is not our only focus, we were happy to find a poster which advocated whistleblowing, regardless of how specific the whistleblowing case may be.

Whistleblowing has become an international phenomenon. While rules and regulations pertaining to whistleblowing are different across national borders, many policy-makers, organizations, non-profits, and advocates are encouraging their citizens to speak up about fraudulent activity that they have witnessed. The U.S. is known to have some of the best whistleblowing protections and rewards programs. Because qui tam laws in the U.S. both protect the whistleblower and reward the whistleblower with a monetary incentive to report fraud, other countries are beginning to model their laws after the U.S.’s. In recent years, UK policy-makers have thought to ramp-up legislation to protect and reward whistleblowers in a similar fashion to the U.S. system.

In the U.S. whistleblowers cannot be fired nor punished in their field for blowing the whistle. Under the most recent law protecting whistleblowers, the Dodd-Frank Act (the new Financial Reform bill), employers cannot “‘discharge, demote, suspend, threaten, harass, directly or indirectly, or in any other manner discriminate against, a whistle-blower in the terms and conditions of employment because of any lawful act done by the whistle-blower’” (for more information on the new U.S. law see “New Financial Reform Law Provides Incentives for Whistleblowers”). Because of these stringent protections, other countries are modeling after the U.S. law. However, it is not only the protections that the U.S. offers whistleblowers, but the monetary incentives that make the U.S. system a good model. In cases that involve recoveries of $1 million or more, the whistleblower must receive a minimum of 10 percent to a maximum of 30 percent of the recovery. (In order to receive a reward the recovery must total $1 million or more.) This means that the lowest possible reward a whistleblower can reap is $100,000.

Because of the advantages of the U.S. qui tam law, some lawmakers in other countries, such as the UK, would like similar protections and rewards for their citizens. It appears that the most recent law protecting whistleblowers in the UK is the Public Disclosure Act 1998, which amends the Employment Rights Act 1996. Under the 1998 Act, citizens can disclose illegal activity including, “a criminal offence; the breach of a legal obligation; a miscarriage of justice; a danger to the health or safety of any individual; damage to the environment; or deliberate covering up of information tending to show any of the above five matters.” Under Part V, “Protection from suffering detriment in employment,” of this law, 47B on “Protected disclosures” states that, “A worker has the right not to be subjected to any detriment by any act, or any deliberate failure to act, by his employer done on the ground that the worker has made a protected disclosure.” Detriment includes a range of punishments including “denial of promotion, facilities or training opportunities which the employer would otherwise have offered.” In this case, a whistleblower in the UK cannot be punished by his employer for whistleblowing if the whistleblower has made a protected disclosure. However, it appears that under these laws, whistleblowers are protected but not rewarded.

Seeing that rewards are what push many to become whistleblowers, UK government officials have questioned whether it should provide such incentives to its citizens. In the “Asset Recovery Action Plan” the Home Office of the UK presents arguments for and against enacting a program similar to the U.S.’s qui tam under the False Claims Act (FCA). Some promising features of the qui tam law that would support the creation similar program include:
• Whistleblowing laws in the U.S. have been “strikingly successful, particularly in defence and healthcare sectors, with many billions of dollars raised annually.”
• “FCA recoveries far exceed the cost of prosecuting fraud—it has been estimated that for every dollar the federal government invests in investigating and prosecuting these case[s], it receives $15 back.”
• It is believed that the law allows for cases to be brought to the attention of the government that otherwise may not have been reported.
• It is believed that, because of qui tam provisions, companies are more likely to comply with the law and avoid committing fraud.
These are advantages to the law in the U.S. that could influence UK policymakers to attempt to create a similar law that would be effective in the UK. However, there are obstacles to qui tam that would require the creation of a similar yet different law that would suit the UK. Qui tam types of provisions have existed since 1790 in the U.S., whereas they would be new to the UK. Legislative differences in U.S. and UK laws would make a law similar to the U.S.’s qui tam hard to implement in the UK because of how unusual it would be in the UK system. Additionally, “Some organizations representing the interests of whistleblowers in the UK have been skeptical about the Qui Tam approach, arguing it would discredit the practice generally.” Because of these similarities and differences the UK government has welcomed debate on the creation of a law similar to the U.S. qui tam law.

This more open debate has sparked further knowledge of whistleblowing and U.S. whistleblowing laws in the UK as it has been reported in The Guardian and other news sources throughout the country. The UK government has not changed its present law, but is certainly on the way to offering a better incentive to blow the whistle.

Sources:
“Asset Recovery Action Plan.” Home Office, the National Archives. 24 May 2007.
http://webarchive.nationalarchives.gov.uk/+/http://www.homeoffice.gov.uk/documents/cons-2007-asset-recovery/asset-recovery-consultation.pdf.
“Asset Recovery Action Plan: A Consultation Document.” Home Office. May 2007.
http://www.lccsa.org.uk/assets/documents/consultation/asset-recovery-consultation.pdf.
“Employment Rights Act 1996.” The National Archives.
http://www.legislation.gov.uk/ukpga/1996/18/contents.
Henning, Peter J. “Come Blow Your Horn for the S.E.C.” The New York Times
DealBook Blog. 26 July 2010. http://dealbook.blogs.nytimes.com/2010/07/26/come-blow-your-horn-to-the-s-e-c/.
Laytons Solicitors. “Whistleblowing.” UK Employment Law. 2005.
http://www.roydens.co.uk/content40.htm.
“Public interest Disclosure Act 1998.” The National Archives.
http://www.legislation.gov.uk/ukpga/1998/23/contents.
Walker, Peter. “Fraud whistleblowers could get cash rewards.” Guardian.co.uk.
24 May 2007. http://www.guardian.co.uk/uk/2007/may/24/ukcrime.immigrationpolicy.
Wylie, Ian. “Whistleblowing that pays.” Guardian.co.uk Money Blog. 1 Feb. 2008.
http://www.guardian.co.uk/money/blog/2008/feb/01/whistleblowingthatpays.

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