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HR Software Provider Achieves Favorable DOJ Resolution

A cloud-based human resource management (“HRM”) software provider faced a U.S. Department of Justice (“DOJ”) investigation related to its role in the Paycheck Protection Program (“PPP”). The DOJ alleged that the company’s platform may have contributed to the submission of inaccurate PPP loan applications, specifically concerning the calculation of payroll costs. FTI Consulting was engaged to conduct an independent assessment of the company’s PPP calculation methodology and evaluate potential exposure in alignment with Small Business Administration (“SBA”) guidance.

Our Impact

The company received a comprehensive, data-driven assessment that provided clarity into its PPP loan calculation methodology and addressed key regulatory concerns.
The analysis demonstrated that the company’s processes did not result in inappropriate activity, helping address the central allegation raised in the DOJ investigation.
Defensible findings from rigorous code review, structured sampling and detailed reconciliations strengthened the company’s position in discussions with regulators.
As a result, the company achieved a favorable resolution with the DOJ, with no evidence of fraud.

Our Role

FTI Consulting, led by the Data & Analytics and Risk & Investigations practices, served as an independent third party to evaluate the integrity of the company’s PPP loan calculation processes.
Our experts conducted a comprehensive review of the company’s code base and designed a statistically informed sampling methodology, analyzing 200 PPP reports across defined strata based on code versions.
In coordination with counsel, the team analyzed 17 iterations of SBA guidance and developed SQL-based models to systematically reconstruct and validate payroll cost calculations.
Our experts performed both automated and manual reconciliations of PPP reports to underlying payroll and HR data and prepared detailed reports and supporting materials for use in discussions with the DOJ.