Government Program Fraud, False Claims Act & Qui Tam Litigation Playbook

Last week, the federal government took another step toward considering the greenhouse gas emissions of suppliers when deciding major Federal agency procurements.  It proposed amendments to the Federal Acquisition Regulation (“FAR”) that would require consideration of the social cost of carbon, and commitments to reduce or mitigate greenhouse gas emissions, in connection with awarding federal contracts. 

State attorneys general are pursuing lawsuits and investigations of alleged inadequate disclosures of climate-related risks.