Government Investigations

Stethoscope on medical bills and health insurance claim form

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.

gavel on a money

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.

Columns at courthouse entrance

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.

Stethoscope and gavel on white background, symbol of law and medic

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.

gavel on a money

States continue to lead the way in actions to enforce consumer protection laws against junk fees across a growing range of industries. In a recent Husch Blackwell Government Enforcement Investigation and Compliance webinar, that included its Antitrust & Competition group, the Texas AG’s cases against junk fees charged by major hotel and booking chains were highlighted and broader state and federal junk fee initiatives were summarized. Since then, two significant new state developments have concentrated attention on junk fees.

a wooden gavel rests on a reflective surface in front of a stock market chart symbolizing the intersection of law and finance

In a rare exercise of federal emergency authority, on July 14, 2026, the Commodity Futures Trading Commission (CFTC) did two things that, individually, would each be unusual and together are noteworthy: it stayed an emergency rule self-filed by a regulated exchange, and then affirmatively ordered that exchange to honor contracts it had already proposed to unwind. The target was KalshiEX LLC (Kalshi), a CFTC-designated contract market (DCM) for event contracts. The catalyst was a Michigan state court order that the CFTC determined raised questions of federal preemption under the Commodity Exchange Act (CEA) and the functioning of a federally regulated derivatives market.

Judge's gavel on table in office

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.

abstract blurred image of doctor and patient people in hospital interior or clinic corridor for background, laboratory, science experiment, health care and medical technology concept, Generative AI

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.