I am pleased to support these changes because I believe they are necessary and appropriate to implement the will of the Congress. I write separately to emphasize one point. We make clear in this item that we intend to make greater use of our forfeiture authority to address program access violations. I believe that this authority should be our first line of defense to curb program access abuses. Our authority to impose such forfeitures is clear and, unlike damages, the imposition of a forfeiture does not require a lengthy, resource intensive proceeding.
Forfeitures are most likely to provide an efficient and effective deterrent.
If the amounts permitted under the forfeiture provisions prove to be an inadequate deterrent to unlawful conduct, I would urge Congress to consider raising those caps to more serious levels as needed. It is my hope that we will use our forfeiture authority as our primary tool of enforcement and only resort to damages proceedings in the most extreme of cases.