Health Law Advisor

What You Need to Know

• A new civil False Claims Act (FCA) Self-Disclosure Pilot Program (SDPP) was announced on October 22, 2026.
• The SDPP, which will run for six months, encourages health care entities to self-disclose potential violations of the FCA and reach resolution on civil liability as well as various administrative penalties.
• The SDPP offers several favorable terms for entities participating in the SDPP, including a lower multiplier and non-claims based calculation methodology for disclosed Anti-Kickback Statute (AKS) violations.

On the final day of the American Health Law Association’s Annual Meeting in New York, officials from the U.S. Department of Justice (DOJ), the Centers for Medicare & Medicaid Services (CMS), and the U.S. Department of Health and Human Services (HHS) Office of Inspector General (OIG) gave their own take on their agencies’ ramped-up enforcement efforts regarding health care fraud in mid-2026.

On April 30, 2026, the Department of Justice (DOJ) announced plans to prioritize “high quality” actions by data miners filing False Claims Act (FCA) qui tam complaints, indicating an ever-growing reliance on FCA whistleblowers as well as technology to uncover fraud, waste, and abuse.

On March 26, 2012, the U.S. Department of Health & Human Services Office of Inspector General (the “OIG”) published a report summarizing a February 23, 2012roundtable meeting between the OIG and compliance professionals from twenty-three pharmaceutical manufacturers.  The compliance officers and other professionals attending the meeting all represented companies currently operating under Corporate Integrity Agreements (or “CIAs”).  CIAs are generally negotiated between a company and the government in connection with settling various types of federal ...