• Assess whether your organization is covered by ARRA.
  • Evaluate the unique allegations that can come under the ARRA whistleblower disclosure provisions.
  • Develop an appreciation of the numerous entities to which a whistleblower may make a protected disclosure.
  • Evaluate the extreme challenges in managing an ARRA whistleblower who remains employed.
  • Assess whether existing compliance and reporting policies, programs and mechanisms are sufficient given the unprecedented sweep of ARRA.
  • Develop additional compliance program features to detect not only fraud but mismanagement and situations creating public danger or violations of regulations and to promote internal reporting.
  • Develop a Rapid Response Plan for addressing any ARRA issues or actual ARRA whistleblower complaints.

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