The U.S. Department of Justice (DOJ) and the Department of Health and Human Services Office of Inspector General (HHS-OIG) unveiled a coordinated voluntary self-disclosure policy that allows healthcare companies to obtain the benefits of both agencies’ disclosure programs through a single submission, marking a significant change in how companies report potential criminal healthcare fraud.
Continue Reading DOJ, HHS-OIG Streamline Healthcare Fraud Self-Disclosures, but Leave Civil FCA Exposure UnaddressedRegister Now: 12th Annual Nashville Healthcare Fraud Conference
Please join us for the 12th Annual Nashville Healthcare Fraud Conference, hosted by Bass, Berry & Sims and the Tennessee Hospital Association. Pending approval, this complimentary program will be eligible for more than eight hours of CLE credit, including ethics. The in-person conference will take place on December 3, 2026, in Nashville, with the same content available virtually on December 10 and 11.
Continue Reading Register Now: 12th Annual Nashville Healthcare Fraud ConferenceDOJ Fraud Division Directive 26-12: Implications for Corporate Fraud Enforcement
On October 1, 2026, Assistant Attorney General Colin M. McDonald issued Directive 26-12, titled “Corporate Enforcement in the Fight Against Fraud.” It directs prosecutors in the National Fraud Enforcement Division (Fraud Division) to pursue healthcare, government, tax, and trade fraud using an “all-tools approach.” The directive also reminds prosecutors to give credit to companies that disclose misconduct, cooperate, and remediate.
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FinCEN Identifies $17.5 Billion in Suspected Healthcare Fraud, Reinforces Prior Warning to Financial Institutions
On September 9, the U.S. Department of the Treasury announced that the Financial Crimes Enforcement Network (FinCEN) had identified approximately $17.5 billion in suspicious financial activity potentially connected to healthcare fraud. Part of the Treasury Department, FinCEN has primary responsibility for administering and enforcing U.S. anti-money laundering laws such as the Bank Secrecy Act (BSA).
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Continue Reading FinCEN Identifies $17.5 Billion in Suspected Healthcare Fraud, Reinforces Prior Warning to Financial InstitutionsStarbucks Settlement Adds to Growing Scrutiny of Corporate DEI Programs
On September 17, Florida Attorney General James Uthmeier announced that Starbucks agreed to pay $1 million and undertake several commitments to resolve a lawsuit alleging that Starbucks engaged in employment practices that violated the Florida Civil Rights Act through race- and sex-based goals, quotas, and preferences. The settlement comes amid increased federal enforcement involving similar practices, including recent FCA settlements involving federal contractors Accenture, Deloitte, and IBM.
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Continue Reading Starbucks Settlement Adds to Growing Scrutiny of Corporate DEI ProgramsGuidance Out, Dismissals In: DOJ Rewrites the False Claims Act Playbook with Justice Manual Revisions on Sub-Regulatory Guidance and Qui Tam Dismissals
Guidance remains relevant as evidence, particularly in healthcare. While guidance cannot establish the underlying legal duty, CMS manuals, Local Coverage Determinations, and similar materials may still be used to prove scienter, notice, industry standards, and medical necessity in FCA cases.
DOJ’s $2 Million Honeywell Settlement Under the Civil Cyber-Fraud Initiative: What Compliance Failures Mean for Defense Contractors
The Department of Justice (DOJ) continues to use the False Claims Act (FCA) to pursue government contractors for alleged failures to comply with contractual cybersecurity requirements. On September 1, DOJ announced that Honeywell Aerospace Inc. agreed to pay $2,042,518 to resolve allegations that a Honeywell business unit failed to comply with required cybersecurity controls under a Department of War (DoW) contract. The settlement is the latest example of DOJ treating cybersecurity compliance as more than an information technology issue. For federal contractors, deficiencies in required cybersecurity controls can also create significant FCA exposure.
DOJ Continues DEI False Claims Act Enforcement with $25 Million Accenture Settlement
On September 14, the U.S. Department of Justice (DOJ) announced that Accenture Federal Services (AFS), Accenture plc, and Accenture LLP (collectively, Accenture or AFS) agreed to pay $25 million to resolve allegations that AFS violated the False Claims Act (FCA) by falsely certifying compliance with anti-discrimination requirements in its federal contracts while engaging in employment practices that allegedly discriminated based on race or sex. Of the $25 million settlement, approximately $11.6 million constitutes restitution, and Accenture denies that it engaged in the alleged conduct.
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Continue Reading DOJ Continues DEI False Claims Act Enforcement with $25 Million Accenture SettlementEleventh Circuit Upholds FCA Qui Tam Provisions Against Appointments Clause Challenge
In a much-anticipated False Claims Act (FCA) ruling, the Eleventh Circuit has joined every other circuit in considering the issue and holding that qui tam relators under the FCA are not “officers of the United States” subject to the Constitution’s Appointments Clause, thereby rejecting the constitutional challenge to the FCA’s qui tam provisions on that narrow ground.
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Medicare Advantage Fraud Enforcement in 2026: What Recent Settlements Reveal About the Limits of Data-Driven False Claims Act Cases
Over the last several months, there has been no shortage of commentary about the Department of Justice’s (DOJ) Fraud Oversight through Careful Use of Statistics (FOCUS) initiative and the rise of data-driven False Claims Act (FCA) investigations. DOJ has made clear that it is increasingly interested in sophisticated analytics, statistical models, and “data miner” relators who use large public datasets to identify potential fraud.
Continue Reading Medicare Advantage Fraud Enforcement in 2026: What Recent Settlements Reveal About the Limits of Data-Driven False Claims Act Cases