On October 22, 2026, the US Department of Justice (DOJ) Civil Division and the US Department of Health and Human Services (HHS) announced a six-month Healthcare False Claims Act Self-Disclosure Pilot Program (FCA SDPP, or the Program), which is set out in a published protocol (the protocol). The Program gives healthcare companies a defined framework for resolving civil False Claims Act (FCA) liability, and related HHS administrative exposure, for potential violations previously unknown to the federal government. In exchange for a complete disclosure, remediation, and repayment, participating companies can obtain a federal FCA release without factual admissions and repay 1.25 to 1.6 times a DOJ-calculated base amount. Submissions are due by 11:59 pm on April 22, 2027; late or partial submissions will not be accepted or reviewed. The defined benefits are notable, but companies must assess the Program’s limits and uncertainties as well as the risks of disclosure before proceeding.
If a company meets the criteria for disclosure under the Program and completes the necessary steps (see below), the Program provides some certainty about what benefits self-disclosure will yield. Most notably:
Repayment terms. A participating company must repay 1.25 to 1.6 times the Base Self-Disclosure Repayment, calculated by DOJ using the financial information submitted. The multiplier will vary based on factors such as the timing of disclosure; the...
On October 22, 2026, the US Department of Justice (DOJ) Civil Division and the US Department of Health and Human Services (HHS) announced a six-month Healthcare False Claims Act Self-Disclosure Pil...