Case Study: Timecard Settlement under the False Claims Act (FCA)

Case Study: Consolidated Nuclear Security LLC's $18.4Million False Claims Act Settlement

On April 23, 2024, the U.S. Department of Justice (DOJ) announced that Consolidated Nuclear Security LLC (CNS), a Tennessee-based contractor managing nuclear weapon facilities for the Department of Energy’s National Nuclear Security Administration (NNSA), agreed to pay $18.4 million to resolve allegations of timecard fraud under the False Claims Act (FCA).

Timework Overview:

Key Findings

  • Duration of  Fraud: The fraudulent activities occurred over a six-year period, from 2014 to 2020.​
  • Nature of Misconduct: CNS employees at the Pantex Plant in Amarillo, Texas, submitted false timekeeping entries, billing the federal government for hours not actually     worked.
  • Financial Breakdown: Out of the $18.4 million settlement, approximately $16.6 million was allocated as restitution for the improperly charged hours.

Implications

  • Potential Penalties: Under the FCA, the government can impose up to treble damages. CNS's proactive disclosure and cooperation likely mitigated the financial penalties they faced. ​
  • Compliance Emphasis: The case underscores the critical importance of accurate timekeeping records for government contractors. Personnel costs are significant in cost-reimbursement agreements, making compliant time records a focal point     for federal agencies. ​

 

Timework Conclusion

Consolidated NuclearSecurity LLC's case serves as a cautionary tale for federal contractors aboutthe severe consequences of timecard fraud. It highlights the necessity forrobust internal controls, accurate record-keeping, and the benefits ofself-disclosure and cooperation with government investigations. This type ofactivity would have been limited or avoided if the entity had responsible timecollection methods and appropriately had implemented a workforce managementsolution.

References:

https://www.feldesman.com/federal-contractors-timecard-fraud-results-in-18-4-million-false-claims-act-settlement/

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