DOJ, HHS launch six‑month Healthcare False Claims Act self‑disclosure pilot
The federal government is giving health‑care providers a new, safer way to self‑disclose alleged false claims under the FDCA.
The Department of Justice and the Department of Health and Human Services announced a six‑month pilot program that allows health‑care providers to self‑disclose alleged violations of the Healthcare False Claims Act (FDCA) in a structured, confidential manner. Under the pilot, institutions can submit a self‑disclosure to a designated government office, receive guidance, and potentially avoid punitive damages or other penalties if they acknowledge and correct the conduct. The program requires participants to complete a written statement describing the alleged misconduct, corrective actions taken, and financial impact, and includes safeguards for confidential treatment of the information until adjudication. The pilot will run through mid‑2027, with the possibility of creating a permanent framework based on findings. Counsel should advise clients on eligibility, timelines, documentation requirements, and how the disclosure could affect existing investigations or claims. Monitoring the program’s outcomes will be essential for anticipating future regulatory expectations and managing risk for large healthcare networks.