DOJ and HHS Open Six-Month FCA Self-Disclosure Pilot With Incentives
The Civil Division and HHS announced a six-month Healthcare False Claims Act Self-Disclosure Pilot Program on October 22, 2026, giving healthcare entities a new, incentive-backed route to self-report FCA violations.
The pilot, announced October 22, 2026 by the DOJ Civil Division and HHS, establishes a dedicated six-month channel for healthcare entities to self-disclose False Claims Act violations outside the standard qui tam referral process, with what the announcement describes as added incentives for qualifying submitters. Medicare- and Medicaid-facing organizations — hospitals, physician groups, home health and durable medical equipment suppliers, managed care plans and drug manufacturers — sit squarely in the audience, alongside the compliance, reimbursement and white-collar defense teams advising them.
The value is timing. Self-disclosure, where it qualifies, can cut off damages exposure and relator claims, but that calculus normally requires months of internal investigation and negotiation; the pilot compresses it into a window that closes quickly. The hard six-month sunset also means silence is a strategic choice, because a disclosure that misses the pilot window may have to be made on ordinary FCA terms.
What to watch: the specific eligibility criteria, the incentive package and the submission mechanics described in the program's terms, which the source alert summarizes only in outline. Practitioners should confirm current terms before advising clients, and should expect early pilot participants to indicate which conduct HHS and DOJ will tolerate.