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ARTICLE · 28 OCTOBER 2026

DOJ And HHS Launch Healthcare False Claims Act Self-Disclosure Pilot Program

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The U.S. Department of Justice and Department of Health and Human Services have launched a six-month pilot program offering healthcare companies a streamlined pathway to resolve potential False Claims Act violations through voluntary self-disclosure. Eligible entities can receive coordinated civil releases without factual admissions or Corporate Integrity Agreements, with repayment limited to 1.25 to 1.6 times actual damages.

United StatesGovernment, Public Sector
John E. Kelly
John E. Kelly
John H. Lawrence
John H. Lawrence
Jacquelyn Papish
Jacquelyn Papish
J.D. Thomas
J.D. Thomas
Michael Phillips
Michael Phillips
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Highlights

  • On Oct. 22, the U.S. Department of Justice (DOJ) Civil Division and the U.S. Department of Health and Human Services (HHS) launched a six-month Healthcare False Claims Act Self-Disclosure Pilot Program (Pilot Program) offering a pathway for healthcare companies to resolve potential civil False Claims Act (FCA) violations.
  • The Pilot Program is open to healthcare providers, suppliers, manufacturers, payors and related entities that bill or are paid, directly or indirectly, by HHS federal healthcare programs, but only for potential FCA violations previously unknown to the federal government.
  • Disclosing companies receive a coordinated civil release under the FCA and certain HHS administrative authorities, with no factual admissions or Corporate Integrity Agreement required, and no imposition of civil monetary penalties or revocation.

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