Listen to this post

The Department of Justice (DOJ) has made it abundantly clear: healthcare fraud remains at the top of its enforcement priorities for 2025 and beyond. In a May 2025 memorandum, Acting Assistant Attorney General Matthew R. Galeotti outlined the Criminal Division’s renewed commitment to “focus, fairness, and efficiency” in the fight against white-collar crime—with healthcare fraud specifically called out as a leading threat.

Healthcare Fraud: Public Enemy Number One

Galeotti’s May 2025 memo, “Focus, Fairness, and Efficiency in the Fight Against White-Collar Crime,” sets the tone for the current administration’s enforcement posture. The memo explicitly identifies “waste, fraud, and abuse, including healthcare fraud and federal program and procurement fraud that harm the public fisc” as the first priority area for the Criminal Division. The memo warns that “rampant healthcare fraud and program and procurement fraud drain our country’s limited resources,” and promises that the DOJ “will lead the fight in holding accountable those who exploit these programs and harm the public fisc for personal gain.”

In June 2025, the DOJ announced the largest health care fraud takedown in U.S. history, charging over 300 individuals—including nearly 100 medical professionals—in schemes involving $14.6 billion in fraudulent claims. These results underscore the DOJ’s commitment to a “whole-of-government” approach, combining criminal and civil enforcement to maximize deterrence and recovery.

Even more recently, in his remarks at the Global Forum on Anti-Corruption and Integrity, Acting AAG Galeotti reiterated that white-collar enforcement such as healthcare fraud remains a top priority, emphasizing the harm such crimes inflict on taxpayers and the healthcare system.

DOJ Expands Healthcare Fraud Enforcement Footprint

The DOJ’s Health Care Fraud Unit currently operates nine Strike Forces across the country, each employing a cross-agency approach that includes the FBI, HHS-OIG, CMS, DEA, and other federal partners. These teams are known for prosecuting large and complex healthcare fraud cases, often involving hundreds of millions of dollars in losses and sophisticated money laundering operations. The Strike Force model is designed to accelerate the detection, investigation, and prosecution of fraud, ensuring that both individual and corporate actors are held accountable.

Announced in September 2025, this move brings the DOJ’s New England Strike Force to the District of Massachusetts, a region recognized as a national leader in healthcare and life sciences. The expansion brings enhanced federal enforcement resources to a state with a long track record of high-impact healthcare fraud investigations and prosecutions.

The False Claims Act: Still the DOJ’s Weapon of Choice

The FCA remains the government’s most powerful tool for recovering taxpayer dollars lost to fraud, waste, and abuse in federal healthcare programs. The DOJ’s recent structural changes and continued investment in FCA enforcement infrastructure signal that healthcare providers, payers, and related entities should expect sustained—and likely increased—FCA scrutiny. Robust compliance, early detection, and voluntary self-disclosure remain the best defenses against the significant risks posed by FCA enforcement actions.

DOJ and HHS Launch New False Claims Act Working Group

On July 2, 2025, the Department of Justice (DOJ) and the Department of Health and Human Services (HHS) announced  the creation of the DOJ-HHS False Claims Act Working Group, an interagency initiative aimed at strengthening the government’s civil enforcement of the False Claims Act (FCA) in the healthcare space. As we explained in an earlier blog post, “While the DOJ and HHS have long worked together to combat fraud, this Working Group marks a formalized, tightly coordinated effort focused on high-impact enforcement areas” and  “is a clear warning shot: healthcare enforcement is becoming more sophisticated, more targeted, and more collaborative.” 

Preparing for Heightened DOJ Scrutiny—Key Steps for Providers and Compliance Professionals

The message from DOJ leadership indicates that health care fraud enforcement is not only here to stay, but is intensifying. Providers and compliance professionals should take note of several key takeaways:

  • Prioritize robust compliance programs that emphasize early detection and remediation of potential fraud, waste, and abuse.
  • Consider voluntary self-disclosure and encourage cooperation, as DOJ policies increasingly reward proactive compliance efforts.
  • Monitor DOJ policy updates and enforcement trends, especially as the Department continues to refine its approach to corporate resolutions, monitorships, and whistleblower incentives.

By taking these steps, healthcare organizations can better manage risk and demonstrate a commitment to integrity in an era of increased federal oversight.

Print:
Email this postTweet this postLike this postShare this post on LinkedIn
Photo of Jody L. Rudman Jody L. Rudman

A seasoned litigator, Jody is passionate about advocating for healthcare clients who face enforcement and compliance issues – both in and out of the courtroom. Jody has assisted clients across a wide range of industries at investigations, negotiations, mediations, pretrial matters, grand jury

A seasoned litigator, Jody is passionate about advocating for healthcare clients who face enforcement and compliance issues – both in and out of the courtroom. Jody has assisted clients across a wide range of industries at investigations, negotiations, mediations, pretrial matters, grand jury proceedings, civil lawsuits, criminal indictments, jury trials, sentencings and appeals.

Photo of Jonathan Porter Jonathan Porter

Jonathan uses his years of experience as a federal prosecutor to guide clients through the challenges associated with government investigations and regulatory compliance.

Jonathan brings to clients a thorough working knowledge of how the U.S. government targets and pursues criminal and civil investigations,

Jonathan uses his years of experience as a federal prosecutor to guide clients through the challenges associated with government investigations and regulatory compliance.

Jonathan brings to clients a thorough working knowledge of how the U.S. government targets and pursues criminal and civil investigations, particularly those involving the healthcare industry. He is a former Assistant U.S. Attorney for the Southern District of Georgia, and in that capacity, he brought charges against numerous individuals and companies under federal law, including criminal charges of health care fraud, wire fraud, and violation of the Anti-Kickback Statute, and civil complaints alleging violations of the False Claims Act.

At the Department of Justice, Jonathan was a key member of multiple international health care fraud takedowns, in which Jonathan charged dozens of doctors, nurses, and other licensed medical professionals, along with marketers and health care executives for alleged participation in healthcare fraud schemes involving billions of dollars in false billings. In total, these charges resulted in more than 30 guilty pleas plus a conviction in the nation’s first trial of a medical professional charged as part of Operation Brace Yourself, which Jonathan first-chaired. Jonathan also was active in dozens of civil investigations brought under the False Claims Act. Jonathan resolved tens of millions of dollars in civil settlements and judgments for False Claims Act violations.

Jonathan also advises clients on a range of regulatory issues, along with the development and implementation of corporate compliance programs. He uses his unique perspective as a former AUSA, providing a prosecutor’s eye for detail in helping clients understand how DOJ and other agencies view compliance, particularly in light of the changing standards for compliance as outlined in the DOJ’s Evaluation of Corporate Compliance Programs (ECCP) and implemented in the Department’s white-collar crime enforcement initiative.

Photo of Kip Randall Kip Randall

A former Army officer, Kip now helps corporate and individual clients navigate government investigations. Kip counsels clients through investigations by the Securities and Exchange Commission (SEC); Environmental Protection Agency (EPA); Internal Revenue Service (IRS); Department of Justice (DOJ), including allegations of antitrust and

A former Army officer, Kip now helps corporate and individual clients navigate government investigations. Kip counsels clients through investigations by the Securities and Exchange Commission (SEC); Environmental Protection Agency (EPA); Internal Revenue Service (IRS); Department of Justice (DOJ), including allegations of antitrust and False Claims Act violations; and state attorneys general. As a member of the eDiscovery Solutions group, Kip works at the intersection of eDiscovery and Government Investigations.

Photo of Kathryn Horvatits Kathryn Horvatits

Kathryn focuses on healthcare regulatory law, leveraging a unique blend of military and medical experience. Kathryn previously served as an emergency action controller and aerospace medical technician in the U.S. Air Force, roles that honed her ability to handle complex, high-pressure situations. Her

Kathryn focuses on healthcare regulatory law, leveraging a unique blend of military and medical experience. Kathryn previously served as an emergency action controller and aerospace medical technician in the U.S. Air Force, roles that honed her ability to handle complex, high-pressure situations. Her interest in law grew out of her military service: she had enjoyed delving into Air Force regulations and using them to argue for and against policy decisions, which naturally led her to the legal field.