By Greg Levine, Beth Weinman and Samantha Barrett Badlam (June 18, 2019, 4:15 PM EDT) -- On May 7, 2019, the U.S. Department of Justice issued guidelines describing when and under what circumstances it will award cooperation credit in False Claims Act matters.[1] Above all else, the new guidelines prioritize the voluntary, proactive and timely self-disclosure of "false claims."[2] The guidelines provide little detail, however, about what kind of information a company should disclose to earn cooperation credit. Nor do they offer any real world examples of actions taken by companies to earn such credit. This kind of detail is especially important when there is a significant disconnect between what the government and a company believe is a legally sound basis for a false claims action....