What the 2026 National Health Care Fraud Takedown Means for Your Agency: A Provider Audit-Readiness Checklist

Introduction

Every year, the U.S. Department of Justice (DOJ) and its partners announce a coordinated, nationwide health care fraud enforcement action known as the National Health Care Fraud Takedown. On June 23, 2026, the Department of Justice announced the 2026 National Health Care Fraud Takedown, which resulted in charges against 455 defendants, including 90 doctors and other licensed medical professionals, for alleged participation in health care fraud and opioid abuse schemes involving more than $6.5 billion in false claims. According to the Department of Health and Human Services Office of Inspector General (HHS-OIG), the action included cases in 56 federal districts and 45 U.S. states and territories, with 50 state Medicaid Fraud Control Units participating.

For most healthcare organizations, a headline about criminal charges can feel distant. The vast majority of home health agencies, hospices, physician practices, clinical laboratories, durable medical equipment (DME) suppliers, behavioral health programs, and other Medicare and Medicaid providers bill honestly and work hard to follow complex rules. Yet the 2026 Takedown is relevant to every provider, not because every provider is under suspicion, but because the tools, data, and priorities that power the Takedown also shape routine Medicare audits, Medicaid audits, claim reviews, and provider enrollment oversight.

This article explains, in plain language, what the 2026 National Health Care Fraud Takedown was, what enforcement trends it revealed, how those trends can affect day-to-day operations at a healthcare agency, and what a practical provider audit-readiness checklist looks like. The goal is educational: to help administrators, compliance officers, billing managers, clinical leaders, and owners understand the current program integrity environment and prepare for Medicare and Medicaid audits with confidence.

What Is the National Health Care Fraud Takedown?

The National Health Care Fraud Takedown is an annual, coordinated enforcement initiative. It is led by the Health Care Fraud Unit of the Department of Justice's Fraud Section, working with U.S. Attorneys' Offices, HHS-OIG, the Federal Bureau of Investigation (FBI), the Drug Enforcement Administration (DEA), the Centers for Medicare & Medicaid Services (CMS), and state Medicaid Fraud Control Units (MFCUs). Charges are filed across many federal districts during a concentrated period and announced together.

The Takedown is closely linked to the Medicare Fraud Strike Force model, a joint effort of DOJ and HHS-OIG analysts, investigators, and prosecutors that targets emerging or migrating fraud schemes. CMS has described the Strike Force as a key component of the Health Care Fraud Prevention and Enforcement Action Team (HEAT), and has noted that many Strike Force charges have resulted from coordinated, multi-district national takedowns.

It is important to understand that the Takedown announcement includes several different types of actions:

• Criminal charges, which are allegations. Every defendant is presumed innocent unless and until proven guilty in court.

• Civil actions and settlements, often under the False Claims Act.

• Administrative actions taken by CMS and HHS-OIG, such as Medicare payment suspensions, billing privilege revocations, and exclusions from federal health care programs.

• DEA administrative actions related to controlled substance registrations.

Administrative actions are especially relevant to healthcare agencies because they do not require a criminal conviction. They are based on program rules and can directly affect cash flow and the ability to bill Medicare and Medicaid.

Key Facts From the 2026 National Health Care Fraud Takedown

Based on official announcements from DOJ and HHS-OIG, the 2026 Takedown included the following highlights:

• 455 defendants charged, including 90 doctors and other licensed medical professionals.

• More than $6.5 billion in alleged false claims tied to health care fraud and opioid abuse schemes, including schemes involving significant patient harm and death.

• Cases in 56 federal districts and 45 U.S. states and territories.

• Participation by 50 state Medicaid Fraud Control Units, which DOJ described as the most in Department history.

• The seizure of more than $182 million in cash, luxury vehicles, jewelry, and other assets.

• CMS payment suspensions for 1,079 providers and billing privilege revocations for 1,403 providers.

• 48 civil monetary penalty settlements totaling more than $73 million.

• More than 1,400 provider exclusions.

• 25 HHS-OIG actions under the Civil Monetary Penalties Law seeking more than $10 billion, tied to payments CMS suspended before they reached providers.

• Civil charges against 13 defendants for $14.8 million in alleged schemes, and civil settlements with 31 defendants totaling $23 million.

• 928 DEA administrative cases since October 1, 2025, seeking revocation of authority to handle or prescribe controlled substances.

DOJ also reported that the Takedown included the largest Medicaid fraud enforcement action in Department history, with 295 defendants charged in schemes involving more than $518 million in alleged false Medicaid claims.

For context, the 2025 National Health Care Fraud Takedown resulted in criminal charges against 324 defendants, with intended losses exceeding $14.6 billion, according to HHS-OIG. The 2026 action involved more defendants but a lower total alleged loss. The comparison shows that dollar totals can vary widely from year to year depending on the size of individual schemes, while the number of defendants, the participation of state partners, and the breadth of administrative actions point to expanding enforcement capacity.

Major Enforcement Trends Healthcare Agencies Should Understand

1. Medicaid Fraud Is a Central Focus

Historically, much federal health care fraud enforcement news focused on Medicare. The 2026 Takedown placed Medicaid at the center. With 50 state MFCUs participating and the largest Medicaid enforcement action in DOJ history, providers that bill state Medicaid programs, including Medicaid managed care organizations, should expect continued attention to Medicaid billing, home and community-based services, personal care services, behavioral health, and other Medicaid-heavy service lines.

This focus also connects to new CMS initiatives. In April 2026, CMS launched the Medicaid Fraud War Room in coordination with the White House Task Force to Eliminate Fraud. CMS reported that in its first 88 days the Medicaid Fraud War Room coordinated actions against 50 unique high-risk Medicaid providers representing approximately $203 million in Medicaid payments. CMS has also published Medicaid program integrity guidance for states, including resources for state-level Medicaid Fraud War Rooms and coordination with MFCUs.

2. Data Analytics and Real-Time Detection

Enforcement agencies have made data analytics a defining feature of their work. In 2025, DOJ announced that it was working with HHS-OIG, the FBI, and other agencies to create a Health Care Fraud Data Fusion Center to use cloud computing, artificial intelligence, and advanced analytics to identify emerging health care fraud schemes. In congressional testimony in March 2026, CMS explained that it links Medicare and Medicaid claims data, provider ownership information, pharmacy records, and external data sources to identify patterns, and that its Fraud Prevention System uses predictive modeling to identify aberrant billing patterns in real time.

CMS also operates the Fraud Defense Operations Center (FDOC), launched in March 2025 and later made permanent. CMS describes the FDOC as a cross-functional team of data analysts, investigators, health policy experts, legal advisors, and law enforcement that works to detect and stop inappropriate billing before claims are paid. In 2025, CMS reported that FDOC efforts resulted in more than $1.8 billion in Medicare payments suspended across 249 providers and suppliers.

For a healthcare agency, the practical meaning is simple: unusual billing patterns are noticed faster than ever. A sudden spike in claims, billing that is out of line with peers, services billed for beneficiaries who live far from the agency, or claims that do not match a provider's staffing or capacity may trigger review even if there is an innocent explanation. Being able to explain and document your billing patterns is now a core part of audit readiness.

3. "Stop and Caught" Instead of "Pay and Chase"

CMS has described a shift away from the traditional "pay and chase" model, in which claims are paid and investigated later, toward what it calls a "stop and caught" approach that stops suspicious payments before they go out the door. In its 2025 annual program integrity report, CMS reported 537 payment suspensions imposed on Medicare providers and suppliers, $5.7 billion on hold at the end of 2025 due to payment suspensions, 5,586 providers and suppliers revoked, and 122,658 Medicare claims denied through pre-payment review.

For providers, this means the first sign of a problem may be a payment suspension, a pre-payment review, or a sudden increase in Additional Documentation Requests (ADRs), rather than a post-payment audit letter months or years later. Agencies need processes that can respond quickly.

4. High-Risk Service Areas

Official announcements from DOJ, HHS-OIG, and CMS have repeatedly identified certain service areas as higher risk for fraud. Recent CMS and DOJ materials point to the following categories:

• Durable medical equipment, prosthetics, orthotics, and supplies (DMEPOS).

• Clinical laboratory testing, including genetic testing and respiratory pathogen panels.

• Wound care and skin substitutes.

• Hospice care.

• Home health services.

• Telemedicine-enabled ordering schemes.

• Behavioral health and substance use disorder treatment.

• Pharmacy billing and controlled substance prescribing.

CMS has taken targeted action in several of these areas. In May 2026, CMS implemented a six-month national moratorium on new Medicare enrollments for home health agencies and hospices, which also applies to certain changes in majority ownership. CMS stated that during the moratoria it would intensify targeted investigations and data analytics, and it reported that recent actions had included the suspension of payments to approximately 800 hospices and home health agencies in Los Angeles suspected of fraud. CMS has also reported stopping more than $1.6 billion in potentially improper Medicare laboratory payments, including the revocation of 157 laboratory providers.

If your agency operates in one of these service lines, it does not mean your agency is suspected of wrongdoing. It does mean your claims are more likely to be reviewed, and your documentation should be ready to support medical necessity, eligibility, and proper ordering.

5. Accountability Beyond the Treating Clinician

DOJ has emphasized accountability for individuals across health care organizations, including owners, executives, marketers, and those involved in billing and business operations, not just treating clinicians. For agency leadership, this underscores the importance of a compliance program that is supported from the top, with clear oversight of referral relationships, marketing practices, and billing operations.

6. Identity Theft and Beneficiary Information Misuse

Several CMS examples involve the misuse of stolen Medicare Beneficiary Identifiers (MBIs) to bill for services never provided. This is relevant to legitimate agencies too. Protecting patient information, verifying patient identity and eligibility at intake, and monitoring for unusual activity under your National Provider Identifier (NPI) helps protect both your patients and your organization from becoming a victim of fraud committed in your name.

What the Takedown Means for Your Agency in Practical Terms

Even if your organization will never be the subject of a criminal case, the enforcement environment reflected in the 2026 Takedown can affect your agency in several practical ways:

• More frequent documentation requests. Medicare Administrative Contractors (MACs), Unified Program Integrity Contractors (UPICs), Recovery Audit Contractors (RACs), the Supplemental Medical Review Contractor (SMRC), and state Medicaid program integrity units may request records more often, especially in high-risk service lines.

• Faster administrative action. Payment suspensions and pre-payment reviews can begin quickly when data shows outlier patterns.

• Closer review of enrollment information. CMS and states are paying close attention to ownership, managing employees, practice locations, and changes of ownership. Inaccurate or outdated enrollment information can lead to deactivation or revocation.

• Greater coordination between Medicare and Medicaid. Information flows more readily between federal and state agencies, so a problem identified in one program may lead to questions in another.

• Increased attention to referral sources and vendors. Relationships with marketers, staffing companies, billing vendors, ordering physicians, and telehealth platforms may be examined.

• Higher expectations for compliance programs. HHS-OIG's General Compliance Program Guidance, published in November 2023, describes the elements of an effective compliance program and is a practical benchmark for agencies of all sizes.

Understanding the Types of Healthcare Audits and Reviews

Audit readiness starts with knowing who may contact you and why. The main types of Medicare and Medicaid reviews include:

Medicare Administrative Contractor (MAC) Reviews

MACs process Medicare fee-for-service claims and conduct medical review. One common program is Targeted Probe and Educate (TPE), in which a MAC reviews a sample of claims, provides education, and may repeat the review if errors continue. Persistent errors after TPE rounds may lead to referral to other contractors or additional action.

Unified Program Integrity Contractor (UPIC) Investigations

UPICs investigate potential fraud, waste, and abuse in Medicare and Medicaid. A UPIC may request records, conduct interviews or site visits, recommend payment suspensions, and refer matters to law enforcement. A UPIC request should always be treated as a high priority.

Recovery Audit Contractor (RAC) Reviews

RACs identify and correct improper payments, typically on a post-payment basis, and can issue overpayment determinations based on their review findings.

Supplemental Medical Review Contractor (SMRC)

The SMRC conducts nationwide medical review on topics identified by CMS, often focusing on specific services or billing issues.

Comprehensive Error Rate Testing (CERT) and Payment Error Rate Measurement (PERM)

CERT measures improper payments in Medicare fee-for-service, and PERM measures improper payments in Medicaid and CHIP. Agencies selected for these reviews must submit records within set timelines. Even though these programs measure error rates, a failure to respond can result in a claim being counted as an error and the payment being recovered.

HHS-OIG Audits and Evaluations

HHS-OIG conducts audits, evaluations, and investigations. OIG audits may focus on a specific provider or a category of services and can result in recommendations for repayment.

State Medicaid Program Integrity and MFCU Activity

State Medicaid agencies conduct their own audits and program integrity reviews, and MFCUs investigate and prosecute Medicaid provider fraud and patient abuse or neglect. Medicaid managed care plans also have their own special investigations units.

The Provider Audit-Readiness Checklist

The following checklist is designed to help healthcare agencies evaluate their readiness for Medicare and Medicaid audits. It reflects commonly recognized compliance practices and official government guidance. Each agency should tailor it to its own service lines, size, payer mix, and state requirements.

Part 1: Compliance Program Foundations

• Confirm that your agency has a written compliance program that reflects the elements described in HHS-OIG's General Compliance Program Guidance, including written policies and procedures, compliance leadership and oversight, training and education, effective lines of communication, enforcing standards, risk assessment, auditing and monitoring, and responding to detected offenses and developing corrective action.

• Designate a compliance officer with enough authority, independence, and time to do the job, and make sure the governing body or owners receive regular compliance reports.

• Maintain a compliance committee or an equivalent structure that meets on a regular schedule and documents its meetings.

• Conduct an annual compliance risk assessment that considers high-risk areas identified by DOJ, HHS-OIG, and CMS, including those highlighted in the 2026 Takedown.

• Review and update your compliance policies at least annually and whenever rules change.

Part 2: Provider Enrollment and Credentialing

• Verify that your Medicare enrollment information in the Provider Enrollment, Chain, and Ownership System (PECOS) is accurate and current, including owners, managing employees, practice locations, and bank account information.

• Confirm that you report changes of information, including ownership and location changes, within the required timeframes.

• Track revalidation due dates for Medicare and each state Medicaid program in which you are enrolled.

• Verify that all clinicians are properly licensed, credentialed, and enrolled, and that licenses are monitored for expiration or discipline.

• If you are a home health agency or hospice, monitor CMS announcements regarding the national enrollment moratoria and understand how they affect planned expansions, new locations, or ownership changes.

Part 3: Exclusion and Sanction Screening

• Screen all employees, contractors, vendors, and referral sources against the HHS-OIG List of Excluded Individuals and Entities (LEIE) before hiring or contracting and on a regular basis afterward, commonly monthly.

• Screen against the federal System for Award Management (SAM.gov) exclusion records.

• Screen against each applicable state Medicaid exclusion list.

• Keep documentation of every screening, including dates and results.

• Have a written process for what to do if a match is found, including immediate escalation to the compliance officer.

Part 4: Clinical Documentation and Medical Necessity

• Confirm that every claim is supported by documentation showing the service was ordered, medically necessary, actually provided, and accurately coded.

• For home health, confirm that documentation supports homebound status, the face-to-face encounter requirement, the plan of care, and certification by an allowed practitioner.

• For hospice, confirm that documentation supports terminal prognosis, the certification and recertification requirements, face-to-face encounters when required, and the election statement.

• For DME, laboratory, and other ordered services, confirm that you have valid orders and that the ordering practitioner had an actual relationship with the patient.

• Confirm that signatures are legible, dated, and compliant with Medicare signature requirements, and that late entries and addenda are clearly marked and explained.

• Review electronic health record templates and copy-and-paste practices so that documentation reflects each patient's individual condition and care.

Part 5: Billing and Coding Integrity

• Conduct regular internal audits of a sample of claims for each service line, with a focus on high-risk services and high-volume codes.

• Consider periodic external audits by an independent reviewer to provide an objective view.

• Track denial rates, ADR rates, and error findings by service type, clinician, and location.

• Compare your billing patterns with available benchmarks. For example, CMS makes Program for Evaluating Payment Patterns Electronic Report (PEPPER) data available to certain provider types, including hospices, home health agencies, and skilled nursing facilities, and has distributed Comparative Billing Reports to selected providers.

• Investigate sudden changes in volume, case mix, or average reimbursement and document the reasons.

• Make sure your billing vendor or clearinghouse follows your compliance standards and that your contract gives you access to records and audit rights.

Part 6: Referral Relationships, Marketing, and Financial Arrangements

• Inventory all financial relationships with physicians, other referral sources, marketers, and vendors.

• Confirm that each arrangement is in writing, reflects fair market value for services actually provided, and does not vary with the volume or value of referrals.

• Review arrangements against the federal Anti-Kickback Statute and, where applicable, the physician self-referral law (the Stark Law), and consult qualified legal counsel for complex arrangements.

• Review marketing practices to make sure staff and contractors do not offer patients gifts, waive cost-sharing improperly, or use high-pressure tactics.

• Review relationships with telehealth platforms and third-party ordering services carefully, as these have been a recurring theme in enforcement actions.

Part 7: Patient Identity, Eligibility, and Data Protection

• Verify patient identity and insurance eligibility at intake.

• Train staff to recognize signs of beneficiary identity misuse, such as patients who do not recall receiving services or claims for patients never seen.

• Monitor remittance advice and Medicare claims data for claims you did not submit under your NPI.

• Maintain HIPAA-compliant privacy and security practices to protect patient information.

Part 8: Overpayments and Self-Disclosure

• Have a written policy for identifying, investigating, quantifying, and returning overpayments. Under the Medicare overpayment rule at 42 CFR 401.305, providers must report and return identified overpayments within the required timeframe. CMS amended this rule effective January 1, 2025, to allow a suspension of the 60-day deadline for up to 180 days while a provider conducts a timely, good-faith investigation of potential related overpayments.

• Track each potential overpayment from discovery to resolution and document the decision-making process.

• Understand the government's voluntary disclosure options, including the HHS-OIG Health Care Fraud Self-Disclosure Protocol for potential fraud and the CMS Voluntary Self-Referral Disclosure Protocol for potential Stark Law violations. Legal counsel should be involved in disclosure decisions.

• Know your state Medicaid program's overpayment reporting and return requirements, which may differ from Medicare.

Part 9: Audit Response Readiness

• Create a written audit response policy that explains how requests are received, logged, routed, and tracked.

• Designate an audit response coordinator and a backup, and make sure front-desk and mailroom staff know to forward any letter from a MAC, UPIC, RAC, SMRC, CERT, PERM contractor, HHS-OIG, state Medicaid agency, MFCU, or law enforcement immediately.

• Maintain a calendar of response deadlines. Missing a deadline can result in automatic denial of the claims under review.

• Before sending records, review them for completeness, legibility, and correct patient identification. Include all relevant documents, such as orders, certifications, plans of care, visit notes, and signature attestations where appropriate.

• Keep an exact copy of everything you send, along with proof of delivery.

• Know when to involve legal counsel. Requests from a UPIC, HHS-OIG Office of Investigations, an MFCU, or any law enforcement agency, as well as subpoenas or civil investigative demands, generally warrant prompt legal advice.

• Prepare staff for possible unannounced site visits. CMS and its contractors conduct site visits to verify that providers are operational and meet enrollment requirements.

Part 10: Payment Suspensions, Denials, and Appeals

• Understand the Medicare payment suspension rules at 42 CFR 405.371 through 405.372, including that CMS may suspend payments based on reliable information of an overpayment or a credible allegation of fraud, and that providers may submit a rebuttal statement under 42 CFR 405.374.

• Understand the Medicaid payment suspension rule at 42 CFR 455.23, which requires states to suspend payments when there is a credible allegation of fraud, subject to good-cause exceptions.

• Understand the Medicare revocation rules at 42 CFR 424.535 and the related appeal rights.

• Know the five levels of the Medicare fee-for-service claims appeal process: redetermination by the MAC, reconsideration by a Qualified Independent Contractor, a hearing before an Administrative Law Judge, review by the Medicare Appeals Council, and judicial review in federal district court.

• Track appeal filing deadlines carefully. For Medicare overpayments, filing a redetermination request within 30 days and a reconsideration request within 60 days of the relevant decision can affect whether recoupment is delayed during the appeal.

• Analyze the root causes of every denial and use the findings to improve documentation and training.

Part 11: Training and Culture

• Provide compliance training to all staff at hire and at least annually, with role-specific training for clinicians, intake staff, coders, and billing staff.

• Train staff on documentation requirements for your specific service lines.

• Maintain an anonymous reporting mechanism, such as a hotline, and a clear non-retaliation policy.

• Investigate every report promptly and document the outcome.

• Recognize that an organization where employees feel safe raising concerns internally is better positioned to correct problems early.

Part 12: Records Retention and Accessibility

• Confirm that your records retention policy meets the longest applicable federal and state requirement for each type of record, including Medicare, Medicaid, Medicare Advantage, and HIPAA documentation requirements.

• Make sure records can be retrieved quickly, including records held by former vendors, closed locations, or legacy electronic systems.

• Make sure records from contracted staff and third parties are included in your record set.

Common Warning Signs That May Draw Attention

Agencies may find it helpful to watch for patterns that program integrity analytics are designed to detect. These are not proof of wrongdoing, and many have legitimate explanations, but they are worth reviewing internally:

• Rapid growth in claims volume or revenue that is not explained by new staff, new locations, or new contracts.

• A high proportion of patients with the same diagnosis, the same services, or the same length of stay.

• Long hospice lengths of stay or high rates of live discharge.

• Home health episodes with patterns that differ markedly from peer agencies.

• A large share of orders from a small number of practitioners, especially practitioners who are not local or who have no other relationship with the patients.

• Patients who live far from the agency's service area.

• Billing for services on dates when staff were not working or when the patient was hospitalized or deceased.

• Repeated billing for tests or items that are normally provided only once.

Regular internal monitoring of these indicators allows an agency to identify and correct issues before they become audit findings.

Steps to Take Right Now

If your agency wants to act on the lessons of the 2026 National Health Care Fraud Takedown, the following practical steps are a reasonable place to start:

1. Review the official DOJ and HHS-OIG announcements and CMS program integrity reports to understand current priorities.

2. Update your compliance risk assessment to reflect the high-risk service areas and the increased focus on Medicaid.

3. Verify your enrollment data in PECOS and your state Medicaid enrollment systems.

4. Run a complete exclusion screening of your workforce, contractors, and vendors.

5. Conduct a focused internal audit of your highest-risk, highest-volume services.

6. Test your audit response process with a mock records request.

7. Review all referral and marketing arrangements with qualified legal counsel.

8. Refresh compliance training for leadership and staff.

9. Confirm that your overpayment policy reflects current Medicare rules.

10. Document everything, including the steps you take to improve.

Frequently Asked Questions

Does the 2026 Takedown mean all providers will be audited?

No. The Takedown targeted specific defendants and schemes. However, the data analytics and administrative tools used in enforcement also guide routine audit selection, so providers in high-risk service areas or with unusual billing patterns may see more review activity.

What is the difference between an audit and an investigation?

An audit or medical review typically examines whether claims met coverage, coding, and documentation requirements. An investigation looks into whether fraud or other misconduct may have occurred. A routine audit can lead to an investigation if serious problems are found, and investigation requests should be handled with legal counsel.

What is a payment suspension?

A payment suspension is an administrative action in which Medicare or Medicaid temporarily withholds payment on claims, often while an investigation or review is underway. Payment suspensions can be imposed before any final finding is made.

Can honest mistakes lead to penalties?

Most billing errors are treated as overpayments that must be returned. Fraud generally involves knowing or intentional conduct, but the False Claims Act also covers reckless disregard and deliberate ignorance. Promptly identifying and returning overpayments, and maintaining an effective compliance program, helps an agency show good faith.

How often should we screen for excluded individuals?

HHS-OIG encourages regular screening of the LEIE. Many organizations screen monthly because the list is updated monthly, and many state Medicaid programs set their own screening requirements.

Why is Medicaid getting more attention now?

Federal agencies have identified Medicaid program integrity as a priority, as shown by the record Medicaid figures in the 2026 Takedown, the participation of 50 MFCUs, and the launch of the CMS Medicaid Fraud War Room in coordination with the White House Task Force to Eliminate Fraud.

Conclusion

The 2026 National Health Care Fraud Takedown reflected an enforcement environment that is more data-driven, more coordinated between federal and state agencies, more focused on Medicaid, and more willing to use administrative tools such as payment suspensions and revocations before money leaves the Medicare and Medicaid trust funds. For healthcare agencies that bill honestly, the best response is not alarm but preparation. A strong compliance program, accurate enrollment information, thorough documentation, regular internal audits, careful oversight of referral and vendor relationships, and a tested audit response process will help any agency respond to a Medicare or Medicaid audit efficiently and protect its ability to serve patients.

How HealthBridge Can Help

HealthBridge is a healthcare management consulting firm that specializes in compliance, audit readiness, and program integrity for healthcare agencies. We can help your organization assess compliance risks, review documentation and billing practices, prepare for Medicare and Medicaid audits, strengthen your compliance program, and respond to records requests with confidence. If you would like support preparing your agency for the current enforcement environment, please get in touch with us. We will be happy to help you with this topic.

References

• U.S. Department of Justice, Office of Public Affairs. National Health Care Fraud Takedown Results in 455 Defendants Charged in Connection with Over $6.5 Billion in Alleged Fraud (June 23, 2026). https://www.justice.gov/opa/pr/national-health-care-fraud-takedown-results-455-defendants-charged-connection-over-65

• U.S. Department of Justice, U.S. Attorney's Office, Eastern District of Michigan. National Health Care Fraud Enforcement Action Results in 455 Defendants Charged and Over $6.5 Billion in Intended Fraud Loss Charged (June 23, 2026). https://www.justice.gov/usao-edmi/pr/national-health-care-fraud-enforcement-action-results-455-defendants-charged-and-over

• U.S. Department of Health and Human Services, Office of Inspector General. 2026 National Health Care Fraud Takedown. https://oig.hhs.gov/newsroom/media-materials/2026-national-health-care-fraud-takedown/

• U.S. Department of Health and Human Services, Office of Inspector General. 2025 National Health Care Fraud Takedown. https://oig.hhs.gov/newsroom/media-materials/2025-national-health-care-fraud-takedown/

• Centers for Medicare & Medicaid Services. National Health Care Fraud Takedown Results in 324 Defendants Charged in Connection with Over $14.6 Billion in Alleged Fraud. https://www.cms.gov/newsroom/press-releases/national-health-care-fraud-takedown-results-324-defendants-charged-connection-over-14-6-billion

• Centers for Medicare & Medicaid Services, Center for Program Integrity. Crushing Fraud: Annual Report 2025. https://www.cms.gov/files/document/crushing-fraud-annual-report.pdf

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• Centers for Medicare & Medicaid Services. CMS Medicaid Fraud War Room Stops More Than $203 Million in Improper Payments During First 88 Days. https://www.cms.gov/newsroom/press-releases/cms-medicaid-fraud-war-room-stops-more-203-million-improper-payments-during-first-88-days

• Centers for Medicare & Medicaid Services. CMS Prevents $1.6 Billion in Fraudulent Medicare Laboratory Payments. https://www.cms.gov/newsroom/press-releases/cms-prevents-1-6-billion-fraudulent-medicare-laboratory-payments

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• U.S. Department of Health and Human Services. CMS Testimony on Combatting Medicare and Medicaid Fraud (March 17, 2026). https://www.hhs.gov/about/agencies/asl/testimony/2026/03/17/cms-testimony-on-combatting-medicare-and-medicaid-fraud.html

• U.S. Department of Justice, Office of Public Affairs. Head of the Criminal Division Matthew R. Galeotti Announces Results of Health Care Fraud Takedown. https://www.justice.gov/opa/speech/supervisory-official-matthew-r-galeotti-delivers-remarks-regarding-health-care-fraud

• U.S. Department of Health and Human Services, Office of Inspector General. General Compliance Program Guidance. https://oig.hhs.gov/compliance/general-compliance-program-guidance/

• U.S. Department of Health and Human Services, Office of Inspector General. Health Care Fraud Self-Disclosure. https://oig.hhs.gov/compliance/self-disclosure-info/

• U.S. Department of Health and Human Services, Office of Inspector General. Exclusions Program and LEIE Database. https://oig.hhs.gov/exclusions/

• U.S. General Services Administration. System for Award Management. https://sam.gov/

• Electronic Code of Federal Regulations. 42 CFR 401.305, Requirements for Reporting and Returning of Overpayments. https://www.ecfr.gov/current/title-42/section-401.305

• Electronic Code of Federal Regulations. 42 CFR 405.371, Suspension, Offset, and Recoupment of Medicare Payments. https://www.ecfr.gov/current/title-42/section-405.371

• Electronic Code of Federal Regulations. 42 CFR 405.374, Opportunity for Rebuttal. https://www.ecfr.gov/current/title-42/section-405.374

• Electronic Code of Federal Regulations. 42 CFR 424.535, Revocation of Enrollment in the Medicare Program. https://www.ecfr.gov/current/title-42/section-424.535

• Electronic Code of Federal Regulations. 42 CFR 455.23, Suspension of Payments in Cases of Fraud. https://www.ecfr.gov/current/title-42/section-455.23

• Centers for Medicare & Medicaid Services. Original Medicare (Fee-for-Service) Appeals. https://www.cms.gov/medicare/appeals-grievances/fee-for-service