A U.S. Court of Appeal in the 3rd Circuit has held that “reckless misclassification” of workers under Davis-Bacon can result in a contractor being liable for charges under the False Claims Act. This is significant because intent to defraud the government is not required and could apply to events that occurred before 2009. United States ex rel. IBEW Local Union No. 98 v. Farfield Co., 2021 U.S. App. LEXIS 20658 (3rd Cir., July 13, 2021).
See here for more information: https://www.lexology.com/library/detail.aspx?g=497a20ab-6f31-4364-bbac-d2edbe52704e