U.S. Justice Department and HHS launch healthcare fraud self-disclosure program

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DOJ, HHS healthcare fraud program

Highlights

The U.S. Department of Justice launched the Healthcare False Claims Act Self-Disclosure Pilot Program, allowing healthcare companies to report violations and seek faster resolutions.
Participating companies must submit full details of misconduct and repay damages using a 1.25 to 1.6 multiplier, with the pilot accepting disclosures through April 22, 2027.
The program incentivizes voluntary internal disclosures and remediation, while the Justice Department will intensify enforcement against companies that fail to cooperate on healthcare fraud.

Program terms and submission window

As announced by U.S. Department of Justice, the Healthcare False Claims Act Self-Disclosure Pilot Program is designed to let healthcare companies report potential violations of the federal False Claims Act and seek a faster resolution of past conduct. The civil pilot is presented as part of a broader effort to make corporate misconduct resolutions more predictable and efficient while still recovering damages and penalties for taxpayers.

Under the program, participating companies must provide all relevant details about conduct that could violate the False Claims Act and submit documents that fully reflect the nature, terms and operation of the disclosed conduct. They also must outline remedial steps already taken and make a financial repayment using a multiplier of 1.25 to 1.6.

The multiplier will vary based on factors including how quickly a company discloses the issue, the duration and scope of the misconduct, whether senior leadership was involved, the financial benefit to the company, and whether the company has successor liability but moved promptly to remediate. In return, companies are to receive a coordinated civil release from liability under the federal False Claims Act and certain HHS administrative authorities.

Submissions may be filed electronically to FCA-SDPP@usdoj.gov, and the pilot will accept disclosures through April 22, 2027. The departments say late or incomplete submissions will not be reviewed.

Enforcement strategy and industry implications

Justice Department officials say the program is meant to create clearer incentives for companies that identify misconduct internally and choose to address it before the government uncovers it through other channels. Assistant Attorney General Brett A. Shumate said voluntary self-disclosure signals a company's commitment to compliance and accountability, while Deputy Assistant Attorney General Brenna Jenny said the department will weigh disclosure, remediation and repayment when determining resolutions.

The program also reinforces the government's intention to focus more heavily on healthcare fraud cases involving companies that do not cooperate. The Justice Department says it will continue pursuing those actors, including in partnership with whistleblowers, while using the pilot to conserve enforcement resources and strengthen oversight of federal healthcare programs.

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