On July 2, 2025, the US Department of Health and Human Services (HHS) and US Department of Justice (DOJ) jointly announced the establishment of the False Claims Act Working Group (FCA Working Group). HHS previously created an FCA Working Group at the end of President Trump’s first term, but little information was publicized about the FCA Working Group’s activities during the Biden administration.

Enforcement priorities

In announcing the FCA Working Group, HHS and DOJ expressed their commitment to strengthen their ongoing collaboration to advance priority enforcement areas. DOJ identified some of these general enforcement priorities in a June 11, 2025, internal DOJ memorandum from the Assistant Attorney General for DOJ’s Civil Division. These included: (1) combatting discriminatory practices and policies; (2) ending antisemitism; (3) protecting women and children; (4) ending sanctuary jurisdictions; and (5) prioritizing denaturalization.

In addition to these general priorities, the FCA Working Group announced and described the following priority enforcement areas.

• The Medicare Advantage Program, also known as Medicare Part C, in which Medicare beneficiaries enroll in private health insurance plans that offer Medicare benefits, which are paid on a per-person basis to provide Medicare-covered benefits to enrolled beneficiaries;
• Drug, device, or biologics pricing, including arrangements for discounts, rebates, service fees, and formulary placement and price reporting;
• ...

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