Key Updates

• The Department of Justice (DOJ) announced a new Fraud Whistleblower Incentive Program (WHIP) on Oct. 20, a three-year pilot program offering discretionary awards from $10,000 to $30,000 to eligible individuals whose tips lead to criminal fraud charges, without requiring a conviction or final resolution of the case.
• The announcement follows DOJ’s Oct. 15 rollout of a coordinated self-disclosure policy with the Department of Health and Human Services Office of Inspector General (HHS-OIG), streamlining the process for companies to voluntarily disclose potential criminal health care fraud.

Why It Matters

• DOJ’s latest initiatives signal an increased focus on detecting and prosecuting fraud involving federal funds, while creating new accelerated incentives for individuals to report suspected misconduct and for companies to voluntarily disclose potential violations. The initiatives are particularly significant for health care providers, government contractors and businesses receiving federal funding.

Next Steps

• Companies should evaluate their internal reporting and investigation procedures to ensure they can promptly identify potential fraud and make informed decisions about voluntary self-disclosure.

WHIP, administered by DOJ’s National Fraud Enforcement Division, is the first federal whistleblower rewards program to offer payments at the charging stage rather than requiring whistleblowers to await the final resolution of an enforcement action. Under the...

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