False Claims Act/Qui Tam Litigation

On August 5, 2026, the U.S. Attorney’s Office for the District of Maryland announced that a Taiwan-based, publicly traded manufacturer of light-emitting diodes and its U.S.-based subsidiary agreed to pay the United States $5.15 million to resolve allegations that they violated the False Claims Act (FCA), common law, and the Tariff Act of 1930 by “knowingly failing to pay duties owed on LEDs imported from China.”

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 U.S. Department of Justice (DOJ) continues to treat Paycheck Protection Program (PPP) loan fraud as an enforcement priority. As we have noted in prior updates covering both criminal and civil enforcement, the pace of new cases has not slowed. Below is an overview of significant PPP-related civil enforcement actions from late 2025 through July 2026. In the coming days, we will post a second blog with an update on criminal enforcement.

On August 4, I spoke with Cormac Connor, Todd Gee, Michael Schrier, and Julia Kopcienski for the latest edition of Husch Blackwell’s Government Enforcement, Compliance & Investigations webinar series. The session examined the federal government’s expanding use of the False Claims Act and other mechanisms to enforce the current administration’s anti-discrimination policy.

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

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.

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.

We just released Episode 44 of the False Claims Act Insights podcast where Bryan Nowicki and I talk about this year’s much publicized string of egregious hospice fraud.

Bryan and I talk about how criminal fraud impacts the hospice industry as a whole, and has a particular collateral consequence on legitimate hospice providers and their