On July 2, 2025, the U.S. Department of Justice (“DOJ”) and the Department of Health and Human Services (“HHS”) announced the formation of the DOJ-HHS False Claims Act Working Group, signaling a continued and coordinated effort to combat healthcare fraud through robust enforcement of the False Claims Act (“FCA”). Creation of this working group is the latest in a series of initiatives DOJ has announced in recent weeks involving use of the FCA to further the Administration’s enforcement priorities. See, e.g., announcement of the Civil Rights Fraud Initiative. And it is consistent with announcements from other corners of DOJ demonstrating that healthcare fraud remains a key focus of this Administration. See, e.g., the Criminal Division’s White-Collar Enforcement Plan, in which health care violations dominated the list of priority areas. See our alert here.

• Membership: The DOJ-HHS False Claims Act Working Group (the “Working Group”) will include senior leadership from HHS, the Centers for Medicare & Medicaid Services (“CMS”), HHS’s Office of Inspector General (“HHS-OIG”), and DOJ’s Civil Division, along with participation from U.S. Attorneys’ Offices nationwide.
• Priority Areas: The Working Group has announced six priority enforcement areas for FCA investigations and prosecutions:
  • Medicare Advantage
  • Drug, device, or biologics pricing (including discounts, rebates, service fees, formulary placement, and price reporting)
  • Barriers to patient access to care (including...

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