Throughout the 20th and 21st centuries, every national crisis in the United States has left a long wake of investigations in its trail at all levels of government. Those governmental investigations and enforcement actions have followed a familiar pattern when arising out of a public crisis.
First, investigative and regulatory bodies at both the federal and state levels target the obvious scammers. In the context of the COVID-19 crisis, this includes obvious frauds such as selling snake oil as a panacea to COVID-19; selling fake tests to consumers and to states; and promising to deliver medical supplies to hospitals, receiving payment from the government, and then disappearing before ever delivering the goods. This “first wave” of enforcement actions generally takes priority among regulators because the conduct at issue directly impacts public safety. Indeed, the Office of the Inspector General (OIG) announced a “strategic plan” outlining the following four goals relating to the enforcement and protection of the Department of Health & Human Services’ (HHS) COVID-19 response and recovery efforts: (1) protect people, (2) protect funds, (3) protect infrastructure, and (4) promote effectiveness of HHS programs—now and into the future. Unsurprisingly, COVID-19’s first wave has already begun.
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