A new six-month pilot program launched by the U.S. Department of Justice ("DOJ") and Department of Health and Human Services ("HHS") allows health care companies that self-disclose previously unknown potential violations of the False Claims Act ("FCA") to obtain a coordinated civil release with no factual admissions, no Corporate Integrity Agreement, and a repayment multiplier in the range of 1.25 to 1.6.
On October 22, 2026, DOJ and HHS launched a health care self-disclosure pilot program ("SDPP") that offers companies a coordinated resolution of civil liability under the FCA (31 U.S.C. § 3729 et seq.) and HHS's revocation and exclusion authorities. The SDPP pertains only to civil conduct; potential criminal conduct must be disclosed to DOJ's National Fraud Enforcement Division.
The SDPP covers only entities paid directly or indirectly by HHS federal health care programs that disclose potential FCA violations "previously unknown to the federal government." Disclosures concerning already-known conduct, while ineligible under this program, may still receive cooperation credit under DOJ's Justice Manual § 4-4.112.
Self-disclosures under the SDPP must be submitted to the email address FCA‑[email protected] by 11:59 p.m. on April 22, 2027, and must:
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