On June 27, 2024, the U.S. Department of Justice (“DOJ”) and the U.S. Department of Health and Human Services, Office of Inspector General (“HHS-OIG”), along with other federal and state law enforcement partners, announced the annual National Health Care Fraud Enforcement Action using criminal enforcement to target a wide variety of alleged health care fraud schemes.
What Has Stayed the Same and What Has Changed?
Similar to last year’s all-encompassing “takedown,” this year’s enforcement action charged defendants with schemes related to telemedicine and laboratory fraud; diversion of controlled substances (HIV medications and prescription stimulants); addiction treatment schemes; opioids and other familiar types of health care fraud (such as home health, DME and kickbacks). However, the “headline” this year was a $900 million case in Arizona involving medically unnecessary amniotic wound grafts.
The 2024 enforcement action charged 193 defendants who allegedly have committed over $2.75 billion in fraud. The cases were brought by 32 different U.S. Attorneys’ Offices and 11 State Attorney Generals’ Offices. Although the dollar figure at issue is slightly higher than the 2023 enforcement action, the number of defendants is strikingly higher, with almost two and a half times as many defendants charged. Similarly, the cases were brought in almost twice as many federal districts as last year, suggesting that the Fraud Section is building more partnerships with U.S. Attorney’s Offices nationwide.
On June 28, 2023, the U.S. Department of Justice (“DOJ”) and the U.S. Department of Health and Human Services, Office of Inspector General (“HHS-OIG”), along with other federal and state law enforcement partners, announced a nationwide health care fraud enforcement action targeting a variety of alleged health care fraud schemes. As has been the case over the last few years, DOJ and HHS-OIG have moved away from categorizing the enforcement action as a “takedown”. The government has not explained the naming change, but one explanation is that it is no longer properly considered a true “takedown” because the enforcement activity (charges, arrests) occurs over many weeks leading up to the day it is announced.
Blog Editors
Recent Updates
- Third Circuit Holds that the Public Disclosure Bar Precludes Qui Tam Actions Based on Information Available on Publicly Accessible Databases
- Supreme Court of Ohio Rules on a Peer-Review Privilege Issue in Stull v. Summa
- Agency Actions Remain Judicially Unreviewable Where Congress Has Legislated Clear Agency Authority - SCOTUS Today
- The Loper and Jarksey Era: Agency Power to Award Civil Penalties in SEC and FINRA Under Increased Scrutiny
- Navigating Regulatory Challenges in the Dietary Supplement Industry: Insights on NJ Assembly Bill No. 1848