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.
Continue Reading DOJ Fraud Division Directive 26-12: Implications for Corporate Fraud Enforcement
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).
Guidance 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 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
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 ProvidersDOJ’s $6.5 Billion National Health Care Fraud Takedown Signals a New Era of Data-Driven Enforcement
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 EnforcementProcurement Fraud Enforcement Trends Continue Into 2026
As procurement fraud enforcement continues to be a priority for the Department of Justice and other federal agencies, we take a look back at significant 2025 enforcement developments affecting government contractors, grant recipients and participants in federal programs in our 2025 Procurement Fraud Review.
Continue Reading Procurement Fraud Enforcement Trends Continue Into 2026Legal Hurdles in Using FCA to Challenge DEI Programs
In a recent article for Law360, I examined the significant challenges the Department of Justice (DOJ) may face as it seeks to use the False Claims Act (FCA) to pursue allegedly unlawful diversity, equity, and inclusion (DEI) practices.
Continue Reading Legal Hurdles in Using FCA to Challenge DEI ProgramsFederal Court Seizes $2 Million from Wound Care Clinic: What Providers, Distributors, and Manufacturers Need to Know
Skin substitutes, bioengineered or natural materials designed to promote healing by replacing or supporting damaged skin, have become a key component of advanced wound care. But the significant Medicare reimbursement of these products commanded over the last few years has made them a prime target for enforcement by the Department of Justice and the Department of Health and Human Services Office of Inspector General (OIG).
Continue Reading Federal Court Seizes $2 Million from Wound Care Clinic: What Providers, Distributors, and Manufacturers Need to KnowTakeaways from IBM’s DEI Settlement
I provided insight for Law360 on the government’s recent settlement with IBM to settle allegations into the company’s diversity, equity and inclusion (DEI) practices. The IBM deal is the first of its kind involving a company and alleged violations of the False Claims Act related to DEI practices. The article suggests this deal may signal the Department of Justice’s (DOJ) focus on enforcement actions involving DEI and the potential fines incurred.
Continue Reading Takeaways from IBM’s DEI Settlement