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Tuesday, July 8, 2025

Health Care Fraud Enforcement Developments: the 2025 Takedown and a “New” False Claims Act Working Group - JD Supra

This year’s National Health Care Fraud Takedown (Takedown) announced recently by the Department of Justice was touted by the Department of Justice (DOJ) as the largest to date, involving over $14.6 billion in “intended loss” and 324 defendants charged. The Takedown reinforces the Trump administration’s commitment to prioritizing health care fraud enforcement, highlights the “significant return on investment” these efforts yield, and repeatedly emphasizes the imperative to prevent fraud before it starts.

Takedown: By the Numbers

To date, the government has:

  • seized over $245 million in cash, luxury vehicles, cryptocurrency, and other assets,
  • blocked reimbursement for over $4 billion claims,
  • brought civil charges against 20 defendants for alleged fraud totaling $14.2 million,
  • settled civil claims against 106 defendants totaling $34.3 million, and
  • brought criminal charges against 324 defendants, including 96 medical professionals.

The $14.6 billion figure reflects the total intended fraud loss charged. Since 2018, DOJ’s method for calculating the “total fraud” has evolved. Initially, the government computed the total fraud based on false billings but then transitioned to measuring actual loss. This year DOJ has focused on the total intended fraud loss, which is not an indicator of actual total losses because it includes claims not actually paid.

Familiar Themes

Consistent with past administrations, DOJ’s latest takedown focuses heavily on criminal charges against individual...



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