On July 2, 2025, the Department of Justice (DOJ) and the Department of Health and Human Services (HHS) announced the creation of the DOJ-HHS False Claims Act Working Group, a high-level interagency initiative aimed at strengthening the government’s civil enforcement of the False Claims Act (FCA) in the healthcare space. While the DOJ and HHS have long worked together to combat fraud, this Working Group marks a formalized, tightly coordinated effort focused on high-impact enforcement areas.
Why This Matters
The FCA is the government’s primary tool for policing fraud in federal programs—including Medicare and Medicaid—and it carries steep penalties. The creation of this Working Group signals a sharpened focus and enhanced capabilities for identifying and prosecuting fraud, particularly in certain hot-button areas.
For healthcare providers, payors, manufacturers, and technology vendors, this means more scrutiny, faster investigations, and a greater likelihood of FCA exposure in 2025 and beyond.
But this Working Group also means that new enforcement leaders could be thinking about ways to reform how FCA is utilized. Members of the Working Group have previously expressed skepticism about how declined qui tams can be abused by relator’s counsel, and so this Working Group could create reforms that both increase government-led enforcement and decrease whistleblower-led enforcement.
What’s New
The Working Group will be jointly led by DOJ’s Civil Division and top HHS legal and...
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