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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 proceedings, civil lawsuits, criminal indictments, jury trials, sentencings and appeals.

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The first half of 2026 has confirmed that False Claims Act (FCA) enforcement is not only continuing at historically elevated levels but is expanding in scope, sophistication, and institutional backing. With the Department of Justice (DOJ) reporting more than $6.8 billion in FCA settlements and judgments for fiscal year 2025 (the highest annual total on record) and qui tam filings on pace to set another record in FY 2026, federal fund recipients across various industries face a sustained period of heightened scrutiny. This mid-year update synthesizes the most significant developments and offers practical considerations for navigating the current enforcement landscape.

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Between May 13 and June 1, 2026, the Department of Justice’s National Fraud Enforcement Division secured six separate jury trial convictions in five federal districts. The defendants span virtually every healthcare setting and role, from a software platform executive to a rural nurse practitioner. In total, alleged losses exceed $1.1 billion to Medicare, Medicaid, and other health benefit programs. The convictions in these cases illustrate and reconfirm the breadth and activeness of the DOJ’s current healthcare fraud enforcement activity.

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On June 4, 2026, The United States Court of Appeals for the Fourth Circuit issued a decision affirming the dismissal of a False Claims Act (FCA) suit for failure to meet Rule 9(b)’s pleading requirements—i.e., failing to state with “particularity the circumstances constituting fraud or mistake.” The decision marks an important victory for FCA defendants faced with vague or imprecise allegations of wrongdoing.

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On June 24, 2026, Acting Attorney General of the United States Todd Blanche along with other senior government officials and leaders announced “the greatest combined federal and state effort in combating healthcare fraud in history.” The 2026 National Health Care Fraud Takedown heralded 455 defendants charged across 56 federal districts and 45 states and territories, in connection with more than $6.5 billion in alleged false claims submitted to Medicare, Medicaid, and other federal health programs—all in a coordinated two-week window.

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How AI-Powered Attacks, Supply Chain Vulnerabilities, and Regulatory Pressures Are Shaping Cybersecurity Today

In today’s digital-first world, cybersecurity has never been more crucial. Organizations across every industry face a rapidly changing threat landscape, with data breaches growing in frequency and sophistication. Modern attackers leverage advancements in technology, particularly artificial intelligence (AI), to launch innovative campaigns that challenge traditional defenses. At the same time, supply chain vulnerabilities and increased regulatory scrutiny are raising the stakes for organizations.

2025 has been a landmark year for False Claims Act (FCA) enforcement, marked by record-breaking settlements, evolving legal theories, and a broadening scope of government priorities. The FCA remains one of the federal government’s most potent tools for combating fraud, with billions recovered annually and an ever-expanding reach into new sectors and compliance areas. This roundup synthesizes the year’s most significant developments—drawing on recent case law and shifting enforcement priorities—and provides actionable insights for businesses navigating the FCA landscape.

This year, the Department of Justice (DOJ) increased its focus on white-collar crime enforcement in some areas, prioritized new areas, and shifted resources away from others. Many of these changes are reflected in Acting Assistant Attorney General Matthew R. Galeotti’s May 12, 2025, memorandum to the DOJ’s Criminal Division (Galeotti Memo), which highlighted 10 high-impact areas of white-collar crime for enforcement:[1]

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Recent Decisions Signal Growing Minority on Challenges to False Claims Act Constitutionality.

Background

The False Claims Act (“FCA”)’s qui tam provisions—which empower private litigants, known as “relators,” to prosecute claims on the Government’s behalf—continue to face constitutional scrutiny, with recent judicial opinions reviving concerns over whether the provisions violate Article II of the U.S. Constitution. As these challenges gain traction, qui tam defendants should be aware of the evolving legal landscape and the potential implications for FCA defense strategies.

On May 12, 2025, the Department of Justice (DOJ) announced revisions to its Corporate Enforcement and Voluntary Self-Disclosure Policy (CEP). As stated by Matthew Galeotti, head of the DOJ’s Criminal Division, the purpose of the revised CEP is to incentivize companies to “come forward, come clean, reform, and cooperate with the government in efficient investigations…