DOJ and HHS Unveil New False Claims Act Self-Disclosure Initiative for Health Care Companies - The National Law Review
Key Updates
- The DOJ and HHS have launched a six-month FCA Self-Disclosure Pilot Program, open through April 22, 2027, offering eligible health care organizations reduced damages and favorable settlement terms for voluntarily disclosing potential civil FCA violations unknown to the federal government.
Why It Matters
- Health care organizations that identify potential FCA violations, such as through audits, compliance investigations, or transactional due diligence, have a limited opportunity to resolve civil liability on more favorable terms by reducing financial exposure and avoiding certain administrative penalties.
Next Steps
- Health care organizations considering participation in the Pilot Program should assess potential FCA exposure and program eligibility, weighing the benefits of self-disclosure against the program’s comprehensive disclosure requirements and other avenues for potential resolution before the April 22 deadline.
Health care organizations now have a six-month window to disclose and resolve potential False Claims Act (FCA) violations with the federal government, in exchange for reduced damages and other favorable settlement terms. This opportunity is offered through the FCA Self-Disclosure Pilot Program, which the Department of Justice (DOJ) Civil Division and Department of Health and Human Services (HHS) jointly launched to incentivize health care companies to self-disclose civil FCA violations that are unknown to the federal government. The Pilot...
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