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
By Richard Arnholt on
Key Takeaways
- DOJ used the FCA to settle with Honeywell Aerospace Inc. for $2,042,518 over allegations that a Honeywell business unit submitted claims for payment under a DoW contract while failing to comply with NIST SP 800-171 cybersecurity requirements incorporated through DFARS 252.204-7012, reinforcing that cybersecurity compliance failures can create significant FCA exposure for defense contractors.
- The settlement arose from a 2022 qui tam whistleblower action filed by a former Honeywell employee, and DOJ reported a record 1,297 qui tam lawsuits filed in FY 2025, underscoring the critical role of internal whistleblowers in driving cybersecurity FCA enforcement under DOJ’s Civil Cyber-Fraud Initiative.
- Notably, the government’s allegations focused on Honeywell’s failure to satisfy required NIST SP 800-171 controls rather than any identified cyberattack or data breach, confirming that FCA risk can arise from a disconnect between contractual cybersecurity obligations and a contractor’s actual compliance posture even in the absence of a security incident.
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.
Continue Reading DOJ’s $2 Million Honeywell Settlement Under the Civil Cyber-Fraud Initiative: What Compliance Failures Mean for Defense ContractorsDOJ Continues DEI False Claims Act Enforcement with $25 Million Accenture Settlement
By Richard Arnholt, Tim K. Garrett & Todd Overman on
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…
Eleventh Circuit Upholds FCA Qui Tam Provisions Against Appointments Clause Challenge
By Matt Curley & Brian Roark on
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.
Continue Reading Eleventh Circuit Upholds FCA Qui Tam Provisions Against Appointments Clause Challenge
Medicare Advantage Fraud Enforcement in 2026: What Recent Settlements Reveal About the Limits of Data-Driven False Claims Act Cases
By Lindsey Fetzer on
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
The Villages Health System Settles Medicare Advantage Risk-Adjustment Allegations for $541.5 Million
By Lindsey Fetzer & Ellen Pasquale on
On August 26, the Department of Justice (DOJ) announced that The Villages Health System, LLC (TVH), a healthcare provider group located within The Villages retirement community in central Florida, agreed to a $541.5 million settlement to resolve False Claims Act (FCA) allegations related to Medicare Advantage risk-adjustment diagnosis codes. The same announcement linked two related settlement agreements, separately executed in late July 2026, where UnitedHealthcare and Florida Blue resolved overpayment recoupment obligations resulting from the same underlying conduct.
Continue Reading The Villages Health System Settles Medicare Advantage Risk-Adjustment Allegations for $541.5 MillionDeloitte DEI Settlement Highlights False Claims Act Risk at Both Federal and State Levels
By Richard Arnholt & Tim K. Garrett on
The U.S. Department of Justice (DOJ) announced on August 25 that Deloitte has agreed to pay $21.5 million to resolve allegations that certain diversity, equity, and inclusion (DEI) practices discriminated against employees and applicants based on race or sex and caused the company to submit false claims for payment under federal contracts. The settlement is…
Medicaid Fraud Enforcement in 2026: High-Risk Areas for Home Care, Behavioral Health and Skilled Nursing Providers
As described in a previous blog post, the 2026 DOJ Health Care Fraud Takedown reflects an increased enforcement focus on Medicaid. Because Medicaid dollars are both federal and state in origin, a single set of allegations can expose a provider to federal FCA liability, state false claims liability, MFCU investigation, state administrative remedies, and HHS-OIG oversight at once. Three areas in particular have drawn recent enforcement attention.
Continue Reading Medicaid Fraud Enforcement in 2026: High-Risk Areas for Home Care, Behavioral Health and Skilled Nursing ProvidersWhat Happens in Vegas…Gets DOJ’s Attention: $95M Wound Care Fraud Indictment
On August 5, the U.S. Department of Justice (DOJ) announced that a federal grand jury in the District of Nevada returned a six-count indictment charging Stephen Dubin, M.D., of Henderson, Nevada, with conspiracy to commit healthcare fraud and five counts of healthcare fraud. The charges against Dr. Dubin arise from an alleged scheme to defraud Medicare of approximately $95 million through the billing of medically unnecessary amniotic wound allografts to elderly Medicare beneficiaries as well as alleged kickbacks and rebates from two allograft distributors; sham full-price invoices; and, as to one distributor, a pass-through bank account held in the name of a shell company. According to DOJ, Medicare paid over $54 million on the allegedly fraudulent claims.
Continue Reading What Happens in Vegas…Gets DOJ’s Attention: $95M Wound Care Fraud Indictment
DOJ’s $6.5 Billion National Health Care Fraud Takedown Signals a New Era of Data-Driven Enforcement
By Denise Barnes & Ben Schrader on
The Department of Justice (DOJ) recently announced the largest National Health Care Fraud Takedown in its history, charging 455 defendants—including 90 physicians and other licensed medical professionals—in schemes involving more than $6.5 billion in alleged false claims.
Continue Reading DOJ’s $6.5 Billion National Health Care Fraud Takedown Signals a New Era of Data-Driven Enforcement