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External Audits, Yearly Reports Part Of Shaw U.'s FCA Compliance Plan

In December, Shaw University settled allegations of False Claims Act (FCA) violations with the National Science Foundation (NSF) Office of Inspector General (OIG). For the first time, RRC is publishing details of the settlement, which were obtained through a federal Freedom of Information Act request (“After Settlement, Shaw University Implements FCA Compliance Plan,” RRC 16, no. 10).

In addition to restitution of $80,329 and penalties of $251,987, Shaw agreed to establish acompliance program within 180 days of the December 2018 settlement. The program includes a compliance officer, compliance committee, various written policies, training and the use of an external auditor to annually review Shaw’s adherence with the terms of the settlement agreement for five years. The audits themselves are to be completed according to a plan submitted to OIG for approval.

First-time and annual training for Shaw employees as well as its contractors and subrecipients are also addressed under the compliance plan, with a minimum length to be followed.

Shaw is required to “institute and maintain a comprehensive training program designed to ensure that each relevant employee is aware of all applicable laws, regulations, and standards of conduct that such individual is expected to follow with regard to NSF awards, and the consequences both to the individual and Shaw University that will ensue from any violation of such requirements.”

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