Any suggestion that the Trump Administration might not be committed to healthcare fraud enforcement was definitively quashed by two recent developments. First, on July 2, 2025, the U.S. Department of Justice (DOJ) and the Department of Health and Human Services (HHS) announced the formation of a new Joint False Claims Act Working Group to coordinate fraud and abuse actions across several agencies. The Working Group will be staffed by members from the HHS Office of General Counsel, CMS’s Center for Program Integrity, the Office of Counsel to the HHS Office of Inspector General (OIG), and the DOJ Civil Division, representing a coordinated effort to reinforce and expand FCA enforcement actions. Second, in late June, DOJ announced a record-breaking 2025 National Health Care Fraud Takedown involving over $14.6 billion in alleged fraud, more than doubling the prior annual record.
Joint False Claims Act Working Group
Focusing first on the Joint False Claims Act Working Group, DOJ leadership expressly identified traditional enforcement priorities, including Medicare Advantage, kickbacks, and drug and device pricing schemes, as continued targets of FCA action. But DOJ’s announcement also emphasized a focus on less traditional priority areas, including network adequacy requirements, barriers to patient access to care, and use of EMR systems to drive inappropriate utilization of care.
DOJ leadership indicated at a recent American Health Law Association conference that the Working...
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