An update on GSA’s transactional data reporting rule

June 9, 2015 — This week on “Off the Shelf” Brian Miller, managing director in the Disputes & Investigations Practice at Navigant, discusses GSA’s transactional data reporting proposed rule.

Miller outlines the mechanics of the rule and analyzes the potential risks to contractors for inaccurate data reporting including the elements of potential Civil False Claims Act liability.

He also highlights the rule’s continuing compliance burden with the ongoing requirement to monitor all contractor commercial sales practices throughout the life of the contract.

Finally, Miller provides insights in recent Civil False Claims Act litigation involving the mandatory disclosure rule and the role of attorney client privilege.