delete PART 25—PROGRAM
Implements the Program Fraud Civil Remedies Act for the Department of Commerce, establishing an administrative adjudication system before ALJs to impose civil penalties (up to $5,500) and assessments (up to twice claim amount) for false, fictitious, or fraudulent claims or statements. Includes discovery, hearing procedures, and appeals for claims under $150,000.
Duplicates the False Claims Act; creates costly administrative apparatus for minor claims where resources would be better allocated; elaborate procedures impose regulatory burden without clear marginal benefit in fraud prevention; enforcement of legitimate fraud concerns can be handled through existing criminal statutes and prioritized civil litigation.