New Division Continues Time-Tested Model: DOJ’s National Fraud Enforcement Division Launches West Coast Health Care Fraud Strike Force

In a further sign that healthcare fraud enforcement remains a top Department of Justice (“DOJ”) priority, on April 30, 2026, the National Fraud Enforcement Division ( “Fraud Division”) announced the launch of the West Coast Health Care Fraud Strike Force (“West Coast Strike Force”).  While the Fraud Division was itself newly created, this latest news is of a piece with the traditional model and enforcement approach of DOJ’s dedicated health care fraud team going back to 2007.  Most recently, DOJ’s Health Care Fraud (“HCF”) Unit—which was absorbed into and renamed the HCF Section within the Fraud Division—announced expansion of its long-running Strike Force program into the District of Massachusetts.  The West Coast Strike Force represents an expansion further still of the HCF Section’s reach.  Consistent with the Strike Force model, the U.S. Attorneys’ Offices for the District of Arizona, District of Nevada, and Northern District of California will partner with HCF Section prosecutors and relevant law enforcement agencies (HHS-OIG, FBI, and DEA) to build cases in the region based on data analytics as well as traditional case sources (cooperators, whistleblowers, and tips).

Long-tenured career personnel who have experience in both corporate and individual healthcare prosecutions, HCF Acting Chief Jacob Foster and Acting Assistant Chief Gary Winters, will be tasked with leading this new regional strike force.  As with any new initiative, we expect that the team will want to showcase public results as a proof of concept and at a minimum, look for press opportunities regarding cases in the pipeline.

Indeed, this team already has a track record of activity in the region, as the announcement highlights accelerating health care fraud trends across all three districts, including the migration of fraud schemes to Arizona and Nevada and the growth of technology-driven health care fraud in Northern California, a significant hub of health care technology.  The announcement points to several recent high-impact prosecutions as the foundation for the new Strike Force, including the conviction of medical technology company executive for COVID-19 health care fraud.

Health Care Fraud Enforcement Continues Under A New Banner

Nationally, since its inception, the HCF Strike Force program has been responsible for the prosecution of over 6,200 defendants who collectively billed federal health care programs and private insurers more than $45 billion. What is new is the Fraud Division’s role as the lead DOJ component, a shift from the prior structure in which the HCF Unit sat within the Fraud Section of DOJ’s Criminal Division.  The creation of the Fraud Division in April 2026, discussed in a prior Sidley update, raised questions about the future of the HCF Unit and whether it would be restructured or refocused. The West Coast Strike Force announcement signals the new Fraud Division has absorbed the HCF Unit with its focus, Strike Force model, and leadership structure largely intact thus far.

Strike Force Announcement Emphasizes Corporate Enforcement in Focus

Interestingly, in addition to encouraging members of the public to report wrongdoing, the West Coast Strike Force announcement invokes DOJ’s corporate enforcement policy (the “CEP”), which contains incentives for companies to voluntarily disclose misconduct.  The inclusion of the CEP, which is focused on corporate criminal enforcement, suggests that the Fraud Division intends to pursue corporate health care fraud cases in addition to pursuing individual prosecutions.  This is not surprising given the increased volume of corporate prosecutions pursued by the HCF team in recent years but is notable given that the tenor of prior announcements around the creation of the Fraud Division seemed to focus more on individual prosecutions.

As Sidley discussed in our March analysis of the CEP, companies should continue to carefully evaluate the risk-reward calculus of voluntary self-disclosure.

This post is as of the posting date stated above. Sidley Austin LLP assumes no duty to update this post or post about any subsequent developments having a bearing on this post.