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.

Why Are Home Care and HCBS Providers a Top Medicaid Fraud Target?

Personal care and home and community-based services (HCBS) remain among the highest-risk areas in Medicaid enforcement. Providers continue to face intense scrutiny, particularly as federal and state agencies increasingly rely on data analytics, beneficiary interviews, and timesheet reviews to identify potential fraud. Common investigative themes include billing for services not rendered, overlapping caregiver shifts, services purportedly delivered while a beneficiary was hospitalized or incarcerated, and documentation that fails to substantiate the hours billed.

Case Study: DOJ and Pennsylvania Charge 19 Defendants in Home Care Timesheet Scheme

Underscoring this risk area, on August 4, 2026, DOJ’s National Fraud Enforcement Division, the U.S. Attorney’s Office for the Eastern District of Pennsylvania, and the Pennsylvania Attorney General jointly charged 19 defendants, both owners and employees of home care companies, for schemes involving more than $4 million in fraudulent claims submitted to Medicare and Medicaid. They alleged that companies submitted time sheets for caregivers who were incarcerated, working other jobs, or even after their own deaths.

What Behavioral Health Billing Practices Are Drawing Medicaid Scrutiny?

Behavioral health has become a recurring focus of Medicaid enforcement, driven by a combination of high utilization, expanded telehealth use, and state-specific coverage requirements. Recent investigations have examined whether treatment records support the frequency and intensity of services billed, whether patients met program eligibility criteria, and whether services were actually performed by properly licensed and credentialed staff.

Case Study: $15.2 Million Judgment Over Kentucky and Ohio Medicaid Day-Treatment Billing

For example, in May 2026, the operators of a children’s behavioral health day-treatment program agreed to a $15.2 million civil judgment to resolve allegations that they billed Kentucky and Ohio Medicaid for time children spent on education, recreation, and lunch breaks.  The government further alleged that some services were billed as if they had been provided by licensed professionals when they were actually performed by lower-level or unqualified personnel. The resolution included a five-year Corporate Integrity Agreement with HHS-OIG, highlighting the coordinated federal-state scrutiny that can arise in Medicaid investigations.

How Are Staffing Shortfalls Becoming False Claims Act Cases for Skilled Nursing Facilities (SNFs)?

SNFs continue to face Medicaid enforcement scrutiny at both the payment and quality-of-care levels. Recent investigations have examined whether services billed to Medicaid were supported by adequate staffing, appropriate resident assessments, and compliance with applicable care requirements. Regulators have also shown a growing willingness to pursue cases alleging that inadequate staffing, deficient resident care, or failure to provide required services rendered Medicaid claims false under federal and state False Claims Acts.

Case Study: Michigan Attorney General Sues Nursing Facility Operator Over $111 Million in Medicaid Claims

To that end, on July 30, 2026, the Michigan Attorney General filed a civil action under the Michigan Medicaid False Claims Act against Fahim Uddin and Pioneer Health Care Management (d/b/a Legacy Healthcare Management), alleging Uddin and his companies accepted more than $111 million in Medicaid reimbursement while failing to maintain staffing levels necessary to provide the services for which they billed, across nine nursing facilities in southeast Michigan.

For a deeper dive into FCA settlements and their implications, we invite you to explore our Healthcare Fraud & Abuse Resource Center, which includes a searchable database of healthcare FCA settlements from the last decade. If you have questions about how recent Medicaid enforcement activity might impact your organization or need guidance on FCA compliance, please contact a member of the Bass, Berry & Sims Healthcare Fraud & Abuse Task Force or one of our Procurement Fraud attorneys.