We just released Episode 49 of the False Claims Act Insights podcast where Lorinda Holloway and I talk about whether insurance can cover False Claims Act investigations and settlements.
Many executives assume fraud exclusions make the answer no, but a recent federal court decision involving government contractor Guidehouse suggests otherwise. We walk through how Guidehouse
Three developments since October 1 extend the buildout of DOJ’s fraud enforcement infrastructure that we covered in our prior post on the Fraud Division’s Priorities Memo and Strike Force expansion. First, Assistant Attorney General Colin M. McDonald of the National Fraud Enforcement Division (the Fraud Division) issued Directive 26-12, a memorandum on the Division’s corporate enforcement priorities (Corporate Enforcement Memo). Second, the U.S. Attorney’s Office for the Eastern District of Pennsylvania (EDPA) announced the creation of an Interagency Fraud Task Force (IFTF) combining the Fraud Division with 14 other federal agencies. Third, on October 7, AAG McDonald issued Directive 26-13, directing a comprehensive, all-tools approach across charging, asset recovery, cooperation, pretrial detention, and sentencing. Together, these developments continue DOJ’s effort to formalize both the substantive standards it will apply to fraud cases and the interagency infrastructure used to identify them.
On September 30, 2026, the University of Missouri-Kansas City School of Law hosted the inaugural Heartland Government Enforcement & Investigations Conference. The day-long program brought together federal prosecutors, judges, state regulators, in-house counsel, and private practitioners across seven substantive sessions spanning DOJ enforcement priorities, federal sentencing and discovery practice, healthcare fraud, legal ethics and artificial intelligence, state antitrust enforcement, internal investigations, and securities and commodities regulation. Below is a summary of each session.
We just released Episode 48 of the False Claims Act Insights podcast where Drew Canning and I discuss what boards can do to avoid False Claims Act problems years in advance through good governance.
While most FCA episodes focus on legal theories, enforcement trends, or specific cases, this conversation examines the strategic and operational decisions
Executive Summary
On September 18, 2026, the Department of Justice (DOJ) announced two substantial revisions to the Justice Manual that will materially affect False Claims Act (FCA) enforcement and defense strategy:
Two announcements in the span of nine days reflect a significant expansion of federal healthcare fraud enforcement resources. On August 4, DOJ announced expansion of its Northeast Health Care Fraud Strike Force to Philadelphia, marking the fourth geographic expansion in less than a year. Nine days later, on August 13, Assistant Attorney General Colin M. McDonald issued a priorities memorandum for the National Fraud Enforcement Division (the Fraud Division), a new DOJ division announced by President Trump in January 2026 and formally established in April 2026, that places healthcare fraud second on a list of five enforcement priorities and describes plans to enhance the Strike Force model with additional resources, data analytics, and technology.
We just released Episode 47 of the False Claims Act Insights podcast where Kip Randall, Abe Souza, and I look at how False Claims Act enforcement has changed so far in 2026.
We discuss how DOJ’s creation of a new fraud division tangentially impacts the False Claims Act, and how 2026 has seen
We just released Episode 46 of the False Claims Act Insights podcast where Robert Hess and I talk about a Ninth Circuit case that opens to door to False Claims Act liability for 340B overcharges.
Rob talks about why 340B is tremendously important to many in healthcare, and why its structure has historically resulted in
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.
We just released Episode 45 of the False Claims Act Insights podcast where Jody Rudman and I talk about this year’s big DOJ healthcare fraud takedown.
We talk about how this year’s takedown compares to those in prior years, and how Medicaid Fraud Control Units participated more than in the past. Jody also unpacks the