Intelligent Waves: The Invoice Said Authorized

In the Intelligent Waves settlement, the Reston-based company and its owner agreed to pay $1.95 million to resolve allegations of false invoices, undelivered quantities and false statements used to obtain Air Force work. The detail that should catch an insider’s eye is what allegedly happened when billed items did not arrive: the company supplied substitutes requested by non-procurement personnel instead of crediting the Air Force for the missing products or labor.

The Justice Department announced the civil settlement on April 3, 2025. It covered flight-data work at Nellis Air Force Base and a separate facilities contract at Edwards Air Force Base.

Nellis Equipment and Invoice Quantities

The Nellis allegations concerned what Intelligent Waves sold, what its invoices described and how much it delivered. The company’s September 2019 Crowd-Sourced Contract provided flight-data collection support and data analytics to the 59th Test and Evaluation Squadron at Nellis Air Force Base.

The government alleged that Intelligent Waves knowingly sold equipment the contract did not authorize, then submitted invoices portraying that equipment as authorized. For a purchasing or billing employee, the useful comparison starts with the contract and the order, then reaches the equipment actually supplied and the description submitted for payment. We examine those records together because a familiar product description on an invoice can conceal the very mismatch an employee sees in the goods.

Billed Quantities Without the Delivery

The government separately alleged that Intelligent Waves knowingly invoiced for products or labor it did not deliver in the quantities stated. The government further alleged that Intelligent Waves failed to credit the Air Force for the undelivered products or labor and supplied substitute products requested by non-procurement personnel instead. We see the absurdity in that account: someone got a substitute while the Air Force was still owed its money.

An insider who worked on credits and account reconciliations may recognize a different part of this story from the employee who handled equipment. One sees the short delivery; another sees whether the customer’s account ever changes. We connect those views to the invoice and the people who knew what it represented.

The Request and the Contract Have Different Jobs

The reference to non-procurement personnel matters because the alleged substitute came from a request outside the purchasing function. A request for a product and the contract’s authorization therefore answer different questions about the same shipment.

A defense contract specifies the work, the basis for payment and the evidence supporting that payment. The contract, its modifications, the relevant line item and the payment request belong in the same comparison. For this kind of allegation, we trace who requested the substitute, what the contract permitted and what the invoice continued to say.

A 2022 study of Defense Department contractors in the International Journal of Management and Humanities found higher fraud penalties among companies with compliance and ethics programs than among those without them. The study compared the presence of programs, without evaluating the organizational culture, budgets or experience of the people running them.

Its discussion also identifies weaknesses in contract surveillance among the vulnerabilities to contracting fraud. Oversight has to reach the equipment and quantities behind the invoice, where an employee can see whether the description matches the work.

The Edwards Award and the Meals for Air Force Employees

The Edwards allegation concerned false statements used to win work. Intelligent Waves entered into the Special Access Program Facilities contract in November 2020 to build facilities at Edwards Air Force Base. The government alleged that the company knowingly made false statements that induced the award.

Nellis concerned equipment and quantities represented in invoices during performance; Edwards concerned statements that allegedly persuaded the Air Force to award a contract. For someone who worked on the proposal or award communications, what the company told the buyer is the starting point for understanding that allegation.

The government also alleged that Intelligent Waves provided meals and entertainment to Air Force employees before award and during performance of both contracts. For an insider who saw those meals or entertainment, the timing connects that knowledge to the award and the work the government paid for.

The Missing Credit Has a Navy Parallel

In a separate case against Inchcape Shipping Services, a whistleblower complaint alleged that estimated bills were not properly reconciled with actual invoices. It described a contract requiring overpayments to be credited to the Navy, then put the amount returned against the amount allegedly overpaid:

The Navy complaint’s credit allegation turned on reconciling estimates to actual invoices; the Nellis allegation turned on accounting for billed products or labor that were not delivered. We see the same taxpayer problem in both allegations: the bill is paid, but the credit owed back never reaches the customer.

The Whistleblower Case

Two former employees brought the whistleblower case under the False Claims Act. Their lawsuit alleged that Intelligent Waves’ owner was aware of some of the alleged wrongful conduct. That is why our assessment follows both the billing discrepancy and who understood it inside the company.

An employee’s account can connect the records behind a defense contractor’s bill to the decisions that produced it. In a matter about unauthorized equipment, missing quantities and substitutes, we work through the difference between what the purchaser was told and what people inside the business understood. That gives the documents their meaning without expecting one employee to know every part of the contract.

A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers. We build the case with you, connecting what you saw in the orders, deliveries and billing to the decisions behind the government’s bill.

You Know What the Invoice Left Out

If you handled an Air Force order, substitute equipment or a missing credit, talk with our whistleblower experts about what the billing concealed. We develop the case with you and bring in defense contract fraud whistleblower lawyers who understand the link between purchasing authority, delivery and payment. You have a partner who stays with you from the first account of the discrepancy through the pursuit of a recovery.