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Tuesday, October 27, 2026

New Department of Justice Health Care Fraud Programs Include First Ever False Claims Act Voluntary Self-Disclosure Policy - Buchanan Ingersoll & Rooney PC

The Department of Justice (DOJ) recently rolled out three initiatives aimed at enhancing the government’s ability to detect healthcare fraud. The three initiatives enlist the private sector in the fight against fraud:

1. The Coordination of Voluntary Self-Disclosure in Health Care Fraud Matters: The DOJ’s National Fraud Enforcement Division (Fraud Division), in collaboration with the Department of Health and Human Services, Office of Inspector General (HHS-OIG), streamlined an administrative hurdle for companies seeking to disclose potential criminal conduct related to federal healthcare programs to reap the benefits of both the DOJ’s Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP) and HHS-OIG’s Health Care Fraud Self-Disclosure Protocol (SDP).

2. The Whistleblower Incentive Program (WHIP): The Fraud Division created the first whistleblower rewards program that pays an upfront award to individuals whose tips lead to criminal charges. WHIP emphasizes submissions involving healthcare fraud.

3. The Healthcare False Claims Act Self-Disclosure Pilot Program (FCA SDPP): The DOJ Civil Division (Civil Division), in collaboration with the HHS-OIG and the Centers for Medicare & Medicaid Services (CMS), announced a six-month pilot program that offers healthcare companies a pathway to resolve civil liability under the False Claims Act by self-disclosing potential violations in exchange for favorable resolution terms, including a civil release from the Civil...



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