DOJ Rule Filing Helps Make White Collar Fraud Enforcement Restructuring Final
On August 18, 2026, the U.S. Department of Justice published a final rule formally establishing the National Fraud Enforcement Division (“NFED”) within DOJ’s organizational regulations and defining the authorities of its Assistant Attorney General. The rule largely formalizes changes announced since April, when DOJ created NFED and began reallocating fraud enforcement responsibilities between the new Division and the Criminal Division.
The final rule gives NFED broad authority over criminal fraud matters, including criminal tax, trade fraud, fraud involving federal funds, healthcare fraud, and related offenses. At the same time, the Criminal Division retains broad fraud authority, leaving DOJ with a more flexible jurisdictional scheme than the public sector/private sector division of labor described by Department leadership in recent months.
We examine how the final rule institutionalizes DOJ’s new white-collar enforcement structure, what it means for the allocation of matters between NFED and the Criminal Division, and the practical implications for companies facing potential exposure across both enforcement portfolios. Click here to read the full post.
DOJ (Re-)Expands Northeast Health Care Fraud Strike Force to Philadelphia and Charges 19 Defendants in Medicaid Home Care Schemes
On August 4, 2026, DOJ’s National Fraud Enforcement Division (“Fraud Division”) announced a significant expansion of its Northeast Health Care Fraud Strike Force into Philadelphia. The expansion will reunite the Fraud Division’s Health Care Fraud Section with the U.S. Attorney’s Office for the Eastern District of Pennsylvania; in 2018, the same teams launched what was then known as the Philadelphia-Newark Regional Strike Force, before reducing its operations to Newark-only in more recent years. Nationally, since its inception in 2007, the Health Care Fraud Strike Force program has been responsible for prosecuting more than 6,200 defendants who collectively billed federal health care programs and private insurers more than $45 billion.
DOJ Grants First Healthcare Declination Under New Corporate Enforcement Policy While Indicting Founder
On July 29, 2026, the Department of Justice (“DOJ”) announced that, consistent with Part I of DOJ’s Department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy (“CEP”), it declined to prosecute Campus Eye Management Holdings LLC and its wholly owned subsidiary, Campus Eye Management LLC (collectively, “Campus Eye”), a management services organization that provided billing and other services to an optometry practice and ambulatory surgery center. DOJ had been investigating Campus Eye for alleged healthcare fraud, including illegal kickbacks. This is the first declination involving a healthcare company under the new, Department-wide CEP. And it is only the second healthcare fraud declination under any voluntary self-disclosure policy in DOJ history—the first being the HealthSun Health Plans, Inc. matter handled by the same team (i.e., the Health Care Fraud Unit) when they were part of the Criminal Division’s Fraud Section, prior to creation of the National Fraud Enforcement Division (“NFED”) earlier this year. Click here to read the full blog post.
DOJ’s 2026 Health Care Fraud Takedown Highlights Increased Coordination and Data-Driven Enforcement
This week, DOJ announced the results of its 2026 National Health Care Fraud Takedown, which involved charges against 455 defendants, including 90 medical professionals, in connection with alleged schemes involving more than $6.5 billion in false claims submitted to Medicare, Medicaid, and other federal health care programs. The Takedown involved the participation of 50 state Medicaid Fraud Control Units and included cases in 56 federal districts and 45 U.S. states and territories.
DOJ’s Civil Rights Fraud Initiative Raises False Claims Act Risks for Healthcare and Life Sciences Companies
In a Reuters article, Sidley partners Jaime Jones, Kristin Graham Koehler and Boyd Greene examine how the U.S. Department of Justice’s Civil Rights Fraud Initiative could create new False Claims Act (FCA) exposure for healthcare and life sciences companies that receive federal funding or contract with the federal government. The initiative seeks to use the FCA to pursue organizations that allegedly violate federal civil rights laws while certifying compliance with contractual, grant or funding requirements.
New Clarity Emerges on DOJ’s Fraud Enforcement Reorganization
In remarks delivered on June 3, 2026, at the American Conference Institute’s Global Anti-Corruption, Ethics & Compliance Conference in New York City, Assistant Attorney General A. Tysen Duva, the head of the U.S. Department of Justice’s (“DOJ”) Criminal Division, provided the clearest public indication to date of how DOJ intends to divide fraud enforcement responsibilities between the Criminal Division’s Fraud Section and the newly created National Fraud Enforcement Division (“NFED”).
Under the emerging structure, NFED will focus on government program fraud, i.e., criminal offenses involving public payers and public systems, including taxpayer-funded programs, while the Criminal Division’s Fraud Section will remain focused on private-sector market, consumer, and corporate fraud matters—a traditional strength of the Unit previously known as Market Integrity & Major Frauds, which will remain part of the Criminal Division. Duva further emphasized that the Fraud Section will be focusing on securities and major financial fraud schemes, global fraud, and prediction markets, and is actively looking to further build capacity by hiring talented lawyers.
The remarks largely confirm earlier expectations that DOJ would eventually provide greater clarity regarding the respective roles of the Criminal Division and NFED following NFED’s creation. We examine what Duva’s comments reveal about DOJ’s enforcement priorities, staffing changes, and the implications for future enforcement activity.
DOJ Signals Increasing Scrutiny of Vertically Integrated Healthcare Companies
On May 19, 2026, Nicole Sarrine, Deputy Assistant Attorney General (DAAG) for Civil Conduct in the U.S. Department of Justice (DOJ) Antitrust Division, signaled increasing suspicion of vertically integrated companies in the healthcare sector in remarks delivered at the Transparency Rising 2026 National Forum.[1] (more…)
DOJ and Texas AG Announce First Settlement in National Investigation of Gender-Affirming Care for Minors
On May 15, 2026, the U.S. Department of Justice and the Texas Attorney General announced the first publicly disclosed settlement arising from the federal government’s nationwide investigation into gender-affirming care for minors. The resolution with Texas Children’s Hospital reflects a coordinated federal-state enforcement approach grounded in False Claims Act (“FCA”) and Federal Food, Drug, and Cosmetic Act (“FDCA”) theories, alongside significant non-monetary remedies extending beyond traditional healthcare fraud settlements. In addition to a substantial monetary payment, the agreements impose operational, clinical, and governance-related obligations that may signal how enforcement authorities intend to pursue similar matters going forward.
This blog post examines the settlement terms, the broader federal policy and enforcement framework underlying the investigation, and the implications for healthcare providers and life sciences companies navigating areas of aligned federal and state enforcement focus. Click to read more about the resolution and what it may signal for future DOJ and state attorney general enforcement activity.
