Overview
Corporations and individuals alike trust Sarah M. Hall, an experienced former federal prosecutor, to represent them in government investigations and prosecutions of the health care, anti-fraud, federal program/procurement, customs/smuggling, public corruption, securities, commodities, environmental, and criminal tax laws.
From her many years as a prosecutor with the U.S. Department of Justice (DOJ), Sarah has extensive experience in every phase of a federal criminal case—from investigation to jury trials to appeals.
Resolving Government Investigations Without Charges
Clients benefit from Sarah’s insight into how prosecutors and law enforcement agents think, investigate, and try cases. With her firsthand knowledge, Sarah vigorously advocates for her client’s interests—and persuades law enforcement agencies to decline to pursue criminal charges or other enforcement actions. Because Sarah’s goal is to resolve government investigations without charges or adverse publicity, many of the most important successes she has achieved for her clients are not publicized. For example, Sarah has obtained multiple federal criminal declinations of prosecution, declinations of civil False Claims Act matters, grants of immunity, and Deferred Prosecution Agreements (DPAs).
Securing Favorable Outcomes in Complex Cases
In matters where the government has brought a case, Sarah has secured numerous favorable criminal and civil resolutions. They include the following:
- no-prison time plea deals,
- sentences that involve far less prison time and financial penalties than requested by the DOJ,
- the resolution of False Claims Act investigations for a fraction of the government’s original demand, and
- the avoidance of administrative penalties such as Corporate Integrity Agreements, suspension and debarment from government contracting, exclusion from federal health care programs, and federal payment suspensions.
Sarah is also ready, willing, and able to take a federal criminal case to trial.
Representing Clients Across White Collar Matters
As a former white collar crime prosecutor, Sarah represents companies and individuals in a wide variety of DOJ white collar criminal investigations and prosecutions. They include cases related to alleged Ponzi schemes and other securities and commodities fraud, criminal government contract fraud, tax fraud, public corruption, conspiracies, extortion, bribery/gratuities, criminal Clean Air Act violations, antitrust violations, and trade laws related to smuggling and tariffs.
Defending Against Health Care Enforcement Actions
As a former health care fraud prosecutor, Sarah devotes a significant part of her practice to representing companies and individuals in criminal and civil (False Claims Act) health care enforcement matters. Sarah defends clients in government investigations brought by Main Justice, U.S. Attorneys’ Offices around the country, and state Attorneys General / Medicaid Fraud Control Units (MFCUs). Her health care clients include:
- nursing homes / skilled nursing facilities (SNFs) and other long-term care facilities,
- SNF Property Companies (PropCos),
- SNF Operating Companies (OpCos),
- SNF management companies,
- private equity and venture capital groups,
- pharmacies,
- medical practices,
- behavioral health providers,
- independent diagnostic testing facilities,
- medical consulting companies,
- physicians,
- medical industry executives, and
- sales representatives.
Sarah has particular experience with Medicare and D.C. Medicaid.
Navigating Non-Health Care False Claims Act Investigations
Outside of the health care world, Sarah regularly represents clients in other types of civil False Claims Act investigations. Her clients have included government contractors, federal grant recipients, and clients under investigation related to their receipt of CARES Act funding, including federal funds under the Paycheck Protection Program (PPP) and the Provider Relief Fund (PRF).
Leading Sensitive Internal Investigations
Clients also look to Sarah to lead sensitive corporate internal investigations. Her experience in internal investigations includes those relating to financial fraud, corruption, workplace culture investigations, health care, FCPA violations, export control violations, narcotics in a corporate setting, #MeToo sexual harassment, and whistleblower retaliation.
A Foundation Built on Government Service and Private Practice
Sarah previously served for seven years as a white collar crime prosecutor with the Fraud Section of DOJ’s Criminal Division. She began her DOJ career as a prosecutor on the highly successful nationwide Medicare Fraud Strike Force, where she gained significant experience prosecuting criminal health care fraud, money laundering, and kickback offenses. While a prosecutor in the Securities and Financial Fraud Unit (now known as the Market, Government, and Consumer Fraud Unit), Sarah investigated and prosecuted some of the most complex financial crimes on Wall Street. Her primary focus was the investigation and prosecution of major global financial institutions, executives, and financial traders.
As a prosecutor, Sarah obtained dozens of convictions, via trial and plea, in six different federal trial courts across the country. Her trial experience includes having served as first chair in federal criminal trials lasting from several weeks to as long as nearly two months in duration.
Before her government service as a DOJ prosecutor, Sarah worked for international law firms, where she defended individuals and corporations in high-profile federal white collar criminal matters, parallel civil and regulatory investigations, and complex civil litigation. Her practice focused on securities/financial fraud, accounting improprieties, and corporate internal investigations.
Prior to her career as a lawyer, Sarah worked on Capitol Hill for a U.S. senator and a U.S. representative. She focused on Finance and Appropriations Committee matters.
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Focus Areas
Services
- White Collar Defense and Internal Investigations
- Health Care and Life Sciences Investigations and Enforcement
- Corporate and Securities Litigation
- Federal and State False Claims Act (Including Qui Tam)
- Fraud and Abuse Compliance Counseling and Defense
- Health Care
- Opioids
- Stark and Self-Referral Laws
- Whistleblowing and Compliance
Experience
Criminal Health Care Fraud
- Represented a long-term care management group in a DOJ criminal investigation related to alleged upcoding. No charges were filed against the client.
- Represented a company in connection with an HHS Office of Inspector General (OIG) whistleblower complaint related to alleged violations of the federal Anti-Kickback Statute in the acquisition of a pharmacy. No claims or charges were brought against the client.
- Represented a pharmacy in connection with a DOJ and OIG criminal investigation into patient kickbacks and billing fraud. No charges were filed against the client.
- Represented a medical doctor in a DOJ and OIG investigation into alleged kickbacks and violations of the Stark Law. No claims or charges were brought against the client.
False Claims Act
- Represented a primary care network in connection with a Medicare Advantage investigation by Main Justice.
- Represented an SNF in connection with a False Claims Act investigation by Main Justice and a state MFCU. No claims were brought against the client.
- Represented a company in a DOJ False Claims Act investigation related to the alleged misuse of federal grant funds. DOJ declined to bring a case against the client.
- Represented a large U.S. defense contractor in a criminal investigation, internal investigation, and civil False Claims Act litigation related to whistleblower allegations of sales of defective combat hardware to the U.S. military.
CARES Act Funding Investigations
- Represented a company in connection with a PPP criminal investigation. No charges were filed against the client.
- Represented a lender in connection with a PPP criminal investigation. No charges were filed against the client.
- Represented a medical facility in connection with an investigation into the receipt of PRF monies. Sarah negotiated a resolution without the government filing suit.
Corporate and Financial Fraud
- Represented a major U.S. company’s former chief financial officer in a criminal investigation, parallel civil and regulatory investigations, and numerous civil litigations filed in the Southern District of New York related to securities and accounting fraud. No charges were brought or civil liability found for the client.
- Represented a former financial controller of a major U.S. company in a U.S. Attorney’s Office for the Southern District of New York criminal case and parallel SEC investigation. Obtained a non-prosecution agreement for the client.
Foreign Corrupt Practices Act
- Represented an individual in a FCPA prosecution brought by the FCPA Unit of DOJ’s Criminal Division, Fraud Section.
Government Contract and Grant Fraud
- Represented a company under investigation for bribery conspiracy. The case was resolved by way of a favorable DPA and a small financial penalty.
- Represented a chief operating officer in a criminal government contract fraud investigation by DOJ and the FBI. No charges were brought against the client.
- Obtained immunity for an individual in a DOJ criminal government contract fraud investigation.
Internal Investigations
- Led an internal investigation for a transportation company regarding financial improprieties and workplace culture. No charges were brought against the client.
- Led an internal investigation for an international motor vehicle company regarding narcotics smuggling and possible FCPA violations. Interfaced with DOJ and investigative agencies in the context of a related federal criminal prosecution. No charges were brought against the client.
- Led an internal investigation for a major charitable foundation in regard to #MeToo sexual harassment allegations spanning a 10-year period.
- Led an internal investigation at a medical consulting company in connection with whistleblower allegations.
Environmental Crimes
- Represented multiple companies and individuals in connection with criminal Clean Air Act indictments related to diesel defeat devices. Sarah obtained declinations of prosecution, no-prison time plea deals, and early release from federal prison.
Other White Collar Criminal Defense
- Represented clients in connection with DOJ Special Counsel investigations. No charges were brought against any client.
Recognition
- Attorney General’s Award for Fraud Prevention, Nominee (2013)
- The Best Lawyers in America: Criminal Defense: White Collar (2023 to 2026), Health Care Law (2026)
- Chambers USA: America’s Leading Lawyers for Business: District of Columbia—Litigation: White-Collar Crime & Government Investigations, "Leader in Their Field" (2024 to 2025)
- Criminal Justice Act (CJA) Felony Panel for the U.S. District Court for the District of Maryland, Panel Member (2018 to present)
- Law360: White Collar Editorial Board (2018)
- Washington, DC, Super Lawyers: White Collar Crimes, Health Care, Civil Litigation (2019 to 2025)
Credentials
Education
- The George Washington University Law School (J.D., with honors, 2001)
- Member, The George Washington International Law Review
- College of William and Mary (B.A., 1997)
- Monroe Scholar
Bar Admissions
- District of Columbia
- Maryland
Court Admissions
- U.S. Court of Appeals for the District of Columbia Circuit
- U.S. Court of Appeals for the Fourth Circuit
- U.S. Court of Appeals for the Second Circuit
- U.S. District Court, District of Columbia
- U.S. District Court, District of Maryland
Professional & Community Involvement
- Edward Bennett Williams American Inn of Court, Barrister
- D.C. Bar Subcommittee on White Collar Crime, Member
Media
Events
Upcoming Events
Past Events
- June 8, 2022
- West / Celesq AttorneysEd Center: The Evolution of Criminal Conspiracy Law and 'Flipping the Script' in United States v. Elizabeth HolmesNovember 2020
- Strafford Webinar: FBI and Other Raids: Guidance for CounselNovember 2019
- ABA National Institute on Health Care Fraud: Negotiating False Claims Act Settlements and MediationMay 2019
- University of Dayton Government Contracting Symposium: Regulations, Compliance and Responsibilities for Government ContractorsJanuary 2019
- Federal Bar Association, District of Columbia Chapter: Current Issues in Government InvestigationsApril 2018
Insights
Insights
- Firm Announcements
Epstein Becker Green Attorneys Honored for Excellence in the Legal Profession by Best Lawyers 2026
12 minute read - BlogsThe First National Health Care Fraud Takedown of the Second Trump Administration: What Stayed the Same and What Is New ...19 minute read
- BlogsThe Record-Setting First National Health Care Fraud Takedown of the Second Trump Administration: What Stayed the Same and ...19 minute read
- Firm Announcements
Epstein Becker Green Recognized by Chambers USA 2025 for Delivering Excellence on Behalf of Healthcare, Labor & Employment ...
5 minute read - Media CoverageSarah M. Hall Quoted in “Trump’s Focus on Medicare Advantage Fraud Poses Enforcement Test”3 minute read
- Firm Announcements
Thirteen Epstein Becker Green Attorneys Named to the 2025 Washington, DC Super Lawyers and Rising Stars Lists
6 minute read - BlogsDOJ Civil Rights Fraud Initiative: FCA Enforcement Expanding Into Alleged Discrimination6 minute read
- BlogsDOJ Announces Initiative to Expand FCA Enforcement Into Alleged Discrimination6 minute read
- BlogsWith New White Collar Enforcement Priorities Memo, DOJ Seeks to Provide More Pathways to Declinations and Non-Prosecution ...5 minute read
- BlogsDepartment of Justice Outlines New White-Collar Crime Enforcement Priorities: Part One5 minute read
- BlogsNew DOJ White Collar Priorities Focus on Health Care Fraud5 minute read
- Media CoverageSarah M. Hall Quoted in “Criminal Health Care Fraud Enforcement Expected to Remain Robust”2 minute read
- Firm Announcements
Epstein Becker Green Attorneys Honored for Excellence in the Legal Profession by Best Lawyers 2025
14 minute read - BlogsDOJ Criminal Fraud Section’s Annual Health Care Fraud Enforcement Action: “We Are a Target-Rich Environment” ...20 minute read
- Firm Announcements
Epstein Becker Green Honored for Exceptional Performance in Key Practice Areas by Chambers USA 2024
5 minute read - BlogsDOJ’s Antitrust Division Launches New Task Force to Target Health Care Monopolies and Collusion6 minute read
- BlogsThe Department of Justice’s Criminal Division Launches a Pilot Program on Voluntary Self-Disclosures for Individuals ...6 minute read
- Firm Announcements
Fourteen Epstein Becker Green Attorneys Named to the 2024 Washington, DC, Super Lawyers and Rising Stars Lists
7 minute read - BlogsThe U.S. Sentencing Commission’s Proposed 2024 Amendments to the Federal Sentencing Guidelines Seek to Restore ...6 minute read
- BlogsMain Justice Launches a 90-Day “Policy Sprint” to Launch a Whistleblower Rewards Program7 minute read
- BlogsDOJ Brings Second Criminal Charges Related to Medicare Advantage Risk Adjustment9 minute read
- BlogsRare DOJ Criminal Indictment Related to Medicare Advantage Risk Adjustment9 minute read
- Firm Announcements
Epstein Becker Green Attorneys Recognized by 2024 Best Lawyers for Excellence in the Legal Profession
12 minute read - BlogsThe 2023 DOJ Health Care Fraud Enforcement (f/k/a “Takedown”): Big Dollars or Clever Packaging?9 minute read
- Media CoverageLaw360’s Hottest Firms and Stories Features Epstein Becker Green Insight on Abortion Takeaways 1 Year After Dobbs1 minute read
- Publications
3 Abortion Enforcement Takeaways 1 Year After Dobbs
2 minute read - Firm Announcements
Thirteen Epstein Becker Green Attorneys Named to the 2023 Washington, DC, Super Lawyers and Rising Stars Lists
4 minute read - Media CoverageSarah M. Hall Quoted in “Executives Face Perils When Confessing to DOJ as Companies Gain”3 minute read
- PublicationsInternal Investigation: Best Practices and Lessons Learned from the Sally Yates Report on Allegations of Abuse in Women’s ...2 minute read
- Publications
The Perils of Navigating Post-Dobbs Anti-Abortion Enforcement Regimes
2 minute read - Firm Announcements
Epstein Becker Green Attorneys Recognized by 2023 Best Lawyers for Excellence in the Legal Profession
11 minute read - Blogs
Post-Dobbs Abortion Enforcement: Nebraska Uses Facebook Messages as Evidence
5 minute read - Blogs
Warning Signs of a Criminal Investigation: Considerations for In-House Counsel and Corporate Executives in a Post-Roe
7 minute read - Blogs
The Impact of Dobbs: Enforcement Risks to Expect and Monitor
8 minute read - Media CoverageSarah M. Hall, Elena Quattrone Quoted in “Conflicting State Laws and 'Unpredictable' Enforcement Await Providers in ...3 minute read
- BlogsPrivate Equity’s Impact on Nursing Home Quality of Care4 minute read
- PublicationsIs Private Equity Really the Boogeyman in Nursing Home Quality of Care?4 minute read
- Firm Announcements
Thirteen Attorneys Named to the 2022 Washington, DC, Super Lawyers and Rising Stars Lists
5 minute read - PublicationsDOJ's 2021 Healthcare Fraud Enforcement Action (or Takedown): New Name, Same Priorities2 minute read
- Media CoverageSarah M. Hall Quoted in “The Insys Case Made History. Why an Exec's Appeal May Not”3 minute read
- Media CoverageSarah M. Hall Featured in “Wake Up Call: Laterals, Moves, In-House”1 minute read
- Media CoverageSarah M. Hall Featured in "Ex-DOJ Prosecutor Joins Epstein Becker in DC"2 minute read
- BlogsA Step Towards Clarity? The NYC Bar Compliance Committee Seeks to Set Forth Guidance on Bringing Enforcement Action Against ...7 minute read
- Media CoverageSarah M. Hall Featured in “Law Firm News—Former Health Care Prosecutor Joins Epstein Becker Green”1 minute read
- Firm AnnouncementsFormer Federal Health Care Prosecutor Sarah M. Hall Joins Epstein Becker Green4 minute read
- PublicationsDOJ’s False Claims Act Recoveries in Fiscal Years 2020 and 2019January 2021
- PublicationsINSIGHT: Nursing Homes Face Heightened Criminal Enforcement During Covid-19June 2020
- PublicationsMitigating Risks in Prescribing and Dispensing Chloroquine and Hydroxychloroquine for COVID-19June 2020
- Publications
The Evolution of Criminal Conspiracy Law and “Flipping the Script” in United States v. Elizabeth Holmes
April 2020 - PublicationsFederal, State Authorities Step Up Efforts to Prevent Hoarding of Chloroquine, Hydroxychloroquine