by Rahul Mukhi, Jennifer Kennedy Park, and Matthew Yelovich
Left to Proper: Rahul Mukhi, Jennifer Kennedy Park and Matthew Yelovich (photographs courtesy of Cleary Gottlieb Steen & Hamilton LLP)
On April 30, 2026, the Division of Justice’s Nationwide Fraud Enforcement Division introduced the creation of the West Coast Well being Care Fraud Strike Power, a multi-district enforcement initiative targeted on Arizona, Nevada, and the Northern District of California. The brand new Strike Power will accomplice prosecutors from the Fraud Division’s Well being Care Fraud Part with the U.S. Attorneys’ Places of work for these districts and can function in coordination with HHS-OIG, the FBI, the DEA, and different legislation enforcement companions.
DOJ described the initiative as a response to information exhibiting a “important and accelerating improve” in well being care fraud throughout the area. The announcement additionally displays DOJ’s continued concentrate on the intersection of well being care, expertise, and federal program reimbursement. Specifically, DOJ singled out Silicon Valley as “floor zero for technology-driven well being care fraud schemes” focusing on taxpayer-funded packages similar to Medicare.
Well being care suppliers, digital well being corporations, pharmaceutical companies, life sciences corporations, and different individuals in federal well being care packages working in these districts ought to put together for elevated scrutiny below the False Claims Act, in addition to below felony well being care fraud, the Anti-Kickback Statute, wire fraud, cash laundering, controlled-substance legal guidelines, and associated statutes.
The announcement comes shortly after DOJ’s creation of the Nationwide Fraud Enforcement Division. Colin M. McDonald was sworn in as its first Assistant Legal professional Common on April 1, 2026. On April 7, 2026, Appearing Legal professional Common Todd Blanche directed the Division to take “speedy motion” to grow to be a strong litigating division targeted on fraud towards taxpayer {dollars} and taxpayer-funded packages.
The West Coast Strike Power additionally builds on DOJ’s long-running Well being Care Fraud Strike Power mannequin. DOJ launched the primary Strike Power in March 2007, combining prosecutors, investigators, and information analytics to establish fraud “sizzling spots” and goal rising schemes. Since then, this system has charged greater than 6,200 defendants who collectively billed federal well being care packages and personal insurers greater than $45 billion.
The announcement additionally follows a report yr for federal well being care fraud enforcement. In Fiscal 12 months 2025, DOJ reported greater than $6.8 billion in False Claims Act settlements and judgments, the very best annual whole in FCA historical past, with greater than $5.7 billion associated to issues involving the well being care trade.[1]
DOJ described the brand new West Coast Strike Power as a response to rising well being care fraud in Arizona, Nevada, and Northern California. The inclusion of the Northern District of California is notable given the district’s focus of digital well being, well being expertise, and growth-stage life sciences corporations.
DOJ additionally highlighted current prosecutions involving digital well being and medical expertise corporations, together with circumstances involving alleged telehealth, prescribing, and diagnostic-testing schemes. These examples underscore that the Strike Power is more likely to focus not solely on conventional supplier fraud, but in addition on enterprise fashions that mix well being care providers, expertise platforms, affected person acquisition, and federal program billing.
- Concentrate on technology-enabled well being care fashions. DOJ’s emphasis on Silicon Valley alerts continued consideration to digital well being, telehealth, well being expertise, diagnostics, and different fashions that could be developed or scaled in Northern California earlier than increasing nationally. Corporations ought to assess whether or not development methods, advertising practices, referral relationships, prescribing protocols, and billing fashions are aligned with federal well being care program necessities.
- Knowledge-driven focusing on. DOJ emphasised that the Strike Power will use information analytics to establish suspicious billing patterns, rising fraud typologies, and schemes that migrate throughout jurisdictions. This emphasis follows the general public unveiling final yr of the Well being Care Fraud Knowledge Fusion Heart, an effort to carry collectively consultants from a number of businesses and “leverage cloud computing, synthetic intelligence, and superior analytics to establish rising well being care fraud schemes.”[2] Corporations with uncommon billing patterns, fast geographic enlargement, high-volume claims, or reliance on novel technology-enabled care fashions might face heightened danger.
- Broad scope of conduct focused. The announcement makes clear that DOJ is concentrated on each conventional and rising well being care fraud schemes, together with Medicaid and Medicare fraud, wound-care and substance-use remedy schemes, digital well being and technology-enabled fraud, controlled-substance diversion, sham operations, and medically pointless providers.
- Self-disclosure incentives. DOJ reiterated that its company enforcement coverage creates incentives for corporations to voluntarily disclose misconduct. We not too long ago mentioned the brand new Division-wide company enforcement coverage right here. Corporations that establish potential points ought to promptly assess whether or not disclosure is acceptable.
[1] See DOJ Proclaims Document-Breaking $6.8 Billion in False Claims Act Recoveries for Fiscal 12 months 2025, Cleary Gottlieb (Jan. 26, 2026), out there right here.
[2] Division of Justice, Nationwide Well being Care Fraud Takedown Leads to 324 Defendants Charged in Reference to Over $14.6 Billion in Alleged Fraud (June 30, 2025), out there right here.
Rahul Mukhi, Jennifer Kennedy Park, and Matthew Yelovich are Companions at Cleary Gottlieb Steen & Hamilton LLP. This submit first appeared as an alert memorandum for the agency.
The views, opinions and positions expressed inside all posts are these of the writer(s) alone and don’t characterize these of the Program on Company Compliance and Enforcement (PCCE) or of the New York College College of Legislation. PCCE makes no representations as to the accuracy, completeness and validity or any statements made on this web site and won’t be liable any errors, omissions or representations. The copyright of this content material belongs to the writer(s) and any legal responsibility as regards to infringement of mental property rights stays with the writer(s).
by Rahul Mukhi, Jennifer Kennedy Park, and Matthew Yelovich
Left to Proper: Rahul Mukhi, Jennifer Kennedy Park and Matthew Yelovich (photographs courtesy of Cleary Gottlieb Steen & Hamilton LLP)
On April 30, 2026, the Division of Justice’s Nationwide Fraud Enforcement Division introduced the creation of the West Coast Well being Care Fraud Strike Power, a multi-district enforcement initiative targeted on Arizona, Nevada, and the Northern District of California. The brand new Strike Power will accomplice prosecutors from the Fraud Division’s Well being Care Fraud Part with the U.S. Attorneys’ Places of work for these districts and can function in coordination with HHS-OIG, the FBI, the DEA, and different legislation enforcement companions.
DOJ described the initiative as a response to information exhibiting a “important and accelerating improve” in well being care fraud throughout the area. The announcement additionally displays DOJ’s continued concentrate on the intersection of well being care, expertise, and federal program reimbursement. Specifically, DOJ singled out Silicon Valley as “floor zero for technology-driven well being care fraud schemes” focusing on taxpayer-funded packages similar to Medicare.
Well being care suppliers, digital well being corporations, pharmaceutical companies, life sciences corporations, and different individuals in federal well being care packages working in these districts ought to put together for elevated scrutiny below the False Claims Act, in addition to below felony well being care fraud, the Anti-Kickback Statute, wire fraud, cash laundering, controlled-substance legal guidelines, and associated statutes.
The announcement comes shortly after DOJ’s creation of the Nationwide Fraud Enforcement Division. Colin M. McDonald was sworn in as its first Assistant Legal professional Common on April 1, 2026. On April 7, 2026, Appearing Legal professional Common Todd Blanche directed the Division to take “speedy motion” to grow to be a strong litigating division targeted on fraud towards taxpayer {dollars} and taxpayer-funded packages.
The West Coast Strike Power additionally builds on DOJ’s long-running Well being Care Fraud Strike Power mannequin. DOJ launched the primary Strike Power in March 2007, combining prosecutors, investigators, and information analytics to establish fraud “sizzling spots” and goal rising schemes. Since then, this system has charged greater than 6,200 defendants who collectively billed federal well being care packages and personal insurers greater than $45 billion.
The announcement additionally follows a report yr for federal well being care fraud enforcement. In Fiscal 12 months 2025, DOJ reported greater than $6.8 billion in False Claims Act settlements and judgments, the very best annual whole in FCA historical past, with greater than $5.7 billion associated to issues involving the well being care trade.[1]
DOJ described the brand new West Coast Strike Power as a response to rising well being care fraud in Arizona, Nevada, and Northern California. The inclusion of the Northern District of California is notable given the district’s focus of digital well being, well being expertise, and growth-stage life sciences corporations.
DOJ additionally highlighted current prosecutions involving digital well being and medical expertise corporations, together with circumstances involving alleged telehealth, prescribing, and diagnostic-testing schemes. These examples underscore that the Strike Power is more likely to focus not solely on conventional supplier fraud, but in addition on enterprise fashions that mix well being care providers, expertise platforms, affected person acquisition, and federal program billing.
- Concentrate on technology-enabled well being care fashions. DOJ’s emphasis on Silicon Valley alerts continued consideration to digital well being, telehealth, well being expertise, diagnostics, and different fashions that could be developed or scaled in Northern California earlier than increasing nationally. Corporations ought to assess whether or not development methods, advertising practices, referral relationships, prescribing protocols, and billing fashions are aligned with federal well being care program necessities.
- Knowledge-driven focusing on. DOJ emphasised that the Strike Power will use information analytics to establish suspicious billing patterns, rising fraud typologies, and schemes that migrate throughout jurisdictions. This emphasis follows the general public unveiling final yr of the Well being Care Fraud Knowledge Fusion Heart, an effort to carry collectively consultants from a number of businesses and “leverage cloud computing, synthetic intelligence, and superior analytics to establish rising well being care fraud schemes.”[2] Corporations with uncommon billing patterns, fast geographic enlargement, high-volume claims, or reliance on novel technology-enabled care fashions might face heightened danger.
- Broad scope of conduct focused. The announcement makes clear that DOJ is concentrated on each conventional and rising well being care fraud schemes, together with Medicaid and Medicare fraud, wound-care and substance-use remedy schemes, digital well being and technology-enabled fraud, controlled-substance diversion, sham operations, and medically pointless providers.
- Self-disclosure incentives. DOJ reiterated that its company enforcement coverage creates incentives for corporations to voluntarily disclose misconduct. We not too long ago mentioned the brand new Division-wide company enforcement coverage right here. Corporations that establish potential points ought to promptly assess whether or not disclosure is acceptable.
[1] See DOJ Proclaims Document-Breaking $6.8 Billion in False Claims Act Recoveries for Fiscal 12 months 2025, Cleary Gottlieb (Jan. 26, 2026), out there right here.
[2] Division of Justice, Nationwide Well being Care Fraud Takedown Leads to 324 Defendants Charged in Reference to Over $14.6 Billion in Alleged Fraud (June 30, 2025), out there right here.
Rahul Mukhi, Jennifer Kennedy Park, and Matthew Yelovich are Companions at Cleary Gottlieb Steen & Hamilton LLP. This submit first appeared as an alert memorandum for the agency.
The views, opinions and positions expressed inside all posts are these of the writer(s) alone and don’t characterize these of the Program on Company Compliance and Enforcement (PCCE) or of the New York College College of Legislation. PCCE makes no representations as to the accuracy, completeness and validity or any statements made on this web site and won’t be liable any errors, omissions or representations. The copyright of this content material belongs to the writer(s) and any legal responsibility as regards to infringement of mental property rights stays with the writer(s).
