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Tuesday, October 27, 2026

DOJ and HHS Launch Healthcare False Claims Act Self-Disclosure Pilot Program - The National Law Review

  • On Oct. 22, the U.S. Department of Justice (DOJ) Civil Division and the U.S. Department of Health and Human Services (HHS) launched a six-month Healthcare False Claims Act Self-Disclosure Pilot Program (Pilot Program) offering a pathway for healthcare companies to resolve potential civil False Claims Act (FCA) violations.
  • The Pilot Program is open to healthcare providers, suppliers, manufacturers, payors and related entities that bill or are paid, directly or indirectly, by HHS federal healthcare programs, but only for potential FCA violations previously unknown to the federal government.
  • Disclosing companies receive a coordinated civil release under the FCA and certain HHS administrative authorities, with no factual admissions or Corporate Integrity Agreement required, and no imposition of civil monetary penalties or revocation.
  • Financial repayment will be based on application of a multiplier between 1.25 and 1.6 times the amount of actual damages and, to be eligible under the Pilot Program, complete submissions must be made by 11:59 p.m. on April 22, 2027.

On Oct. 22, 2026, DOJ’s Civil Division, in partnership with HHS, announced the Healthcare False Claims Act Self-Disclosure Pilot Program, “which is designed to give healthcare companies a way to quickly resolve past misconduct” by self-disclosing potential violations of the federal FCA. The Pilot Program will accept submissions for six months, through April 22, 2027.

Background

DOJ and HHS have recently ushered in a...



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