Denise Barnes

Denise Barnes counsels clients in high-stakes matters related to fraud allegations, including in healthcare, federal contract procurement, and securities and financial services. A former trial attorney with the U.S. Department of Justice (DOJ), she has extensive experience handling issues related to compliance, white-collar and regulatory investigations, and complex commercial litigation. Denise represents businesses in public and non-public investigations, regulatory inquiries, and proceedings involving federal and state agencies. She frequently assists clients navigating government investigations related to allegations arising under the False Claims Act (FCA), Anti-Kickback Statute (AKS), Stark Law, and Financial Institutions Reform, Recovery, and Enforcement Act (FIRREA). Notably, during her tenure at the DOJ, she spearheaded numerous multi-district investigations that resulted in over $2.7 billion in recoveries for federal taxpayers.

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Understanding the False Claims Act Implications of Trump’s Latest DEI Order for Federal Contractors

By Denise Barnes on March 30, 2026

Posted in Compliance, Escobar, Falsity, FCA Alert, Government Contracts

I recently shared my perspective on President Trump’s newest executive order, which is designed to restrict federal contractors from participating in what the administration characterizes as “racially discriminatory” DEI efforts. Under this order, certain DEI‑related activities could put a contractor’s eligibility for future federal work at risk.

HHS-OIG’s Latest Wound Care Report Warrants Careful Scrutiny

By Denise Barnes, Angela Bergman & Garrah Carter-Mason on October 13, 2025

Posted in FCA Alert, Medicare Advantage, Medicare/Medicaid

On September 9, the U.S. Department of Health and Human Services Office of the Inspector General (HHS-OIG) released a major report (Report) regarding the fraud risks currently associated with skin substitute products billed to Medicare.

Cracking Down on Customs Fraud: How the False Claims Act Raises the Stakes for Importers

By Denise Barnes on October 13, 2025

Posted in Business & Industry Focus, Enforcement, FCA Alert, Whistleblower

The federal government’s growing use of the False Claims Act (FCA) to pursue customs fraud signals a new era of trade enforcement, with importers facing heightened scrutiny and increased risk of whistleblower actions.

Wound Care in the Crosshairs: Reimbursements Risks Amid Skin Substitute Fraud Investigations

By Kristin Bohl, Denise Barnes & Garrah Carter-Mason on June 23, 2025

Posted in Enforcement, Falsity, FCA Alert, Healthcare Providers

Effective wound care is critical for patients recovering from surgery or managing chronic or non-healing wounds. Advances in treatment have led to the development of skin substitutes—bioengineered or natural materials designed to promote healing by replacing or supporting damaged skin. While these innovations hold great promise for the future of wound care, they have also come under increased scrutiny by regulatory agencies and the Department of Justice (DOJ).

DOJ’s New Civil Rights Fraud Initiative – Expect Increased Enforcement

By Richard Arnholt, Denise Barnes, Scott Gallisdorfer & Tim K. Garrett on May 21, 2025

Posted in FCA Alert, Government Contracts

On May 19, the Department of Justice (DOJ) announced the launch of the Civil Rights Fraud Initiative, which will use the federal False Claims Act (FCA) to pursue claims against recipients of federal funds that knowingly violate federal civil rights law.

Continue Reading on the GovCon & Trade blog

DOJ’s Latest False Claims Act Customs Fraud Intervention

By Denise Barnes, Lindsey Fetzer & Thad McBride on May 16, 2025

Posted in Enforcement, FCA Alert

We authored an article for Law360 outlining a recent Department of Justice (DOJ) intervention in a False Claims Act (FCA) customs fraud matter.

Key Takeaways from DOJ’s Continued Cybersecurity Enforcement

By Denise Barnes & Taylor Sample on April 15, 2025

Posted in Compliance, Cybersecurity, Government Contracts, Whistleblower

On March 25, the U.S. Department of Justice (DOJ) announced a $4.6 million settlement with MORSECORP, Inc. (MORSE) over its alleged failures to satisfy cybersecurity requirements for federal defense contractors.

False Claims Act Gives Broad Dismissal Authority to Government, District Judge Says

By Richard Arnholt & Denise Barnes on April 14, 2025

Posted in Compliance, Counterclaims, Courts, Government Contracts, Granston Memo, Knowledge/Scienter, Relators, Whistleblower

On April 2, the United States District Court for the Eastern District of Virginia dismissed a whistleblower’s False Claims Act (FCA) action after the relator attempted to dismiss the government as a plaintiff-intervenor in the lawsuit.

Continue reading on the GovCon & Trade blog.

Impact of Trump Administration’s Executive Order on DEI Programs and FCA Liability

By Denise Barnes & Scott Gallisdorfer on February 13, 2025

Posted in Civil Investigative Demands, Civil Monetary Penalties, Compliance, Damages, Enforcement, FCA Alert, Government Contracts, Government Knowledge, Healthcare Providers, Hospitals, Knowledge/Scienter, Legislation, Materiality, Medicare/Medicaid, Penalties, Public Disclosure Bar, Retaliation, Whistleblower

As federal contractors and grant recipients navigate the changing landscape of diversity, equity, and inclusion (DEI) programs, the Trump administration’s rescinding of Executive Order No. 11246 (EO) raises new concerns about potential False Claims Act (FCA) liability for non-compliance.

Executive Order on DEI Programs: Implications for Healthcare and False Claims Act Risks

By Denise Barnes on February 13, 2025

Posted in Clinical Laboratories, Compliance, Enforcement, FCA Alert, Government Contracts, Healthcare Providers, Legislation, Medicare/Medicaid, Whistleblower

The Trump administration’s recent executive order targeting diversity, equity, and inclusion (DEI) programs is reshaping the landscape for healthcare providers, with potential legal and regulatory implications that are still unfolding.

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Inside the False Claims Act