DOJ and HHS-OIG Report a Record Year of Enforcement, With Healthcare Fraud at the Center

The U.S. Department of Justice (DOJ)’s Criminal Division Fraud Section closed 2025 with what it characterized as a “record-setting” year, marked by a renewed emphasis on corporate enforcement and a sharp increase in charged defendants. Nearly 75% of these defendants were charged with some form of healthcare fraud — an unmistakable signal that this remains a core enforcement priority.

That emphasis — discussed in the Fraud Section’s newly released 2025 Year in Review (Year in Review) — aligns closely with the U.S. Department of Health and Human Services Office of Inspector General (HHS-OIG)’s recent Semiannual Report to Congress (Semiannual Report). Read together, the two reports provide a clear picture of where federal enforcement is headed —and where risk is most acute for healthcare providers, life sciences companies, managed care organizations, and digital health platforms.

A Record Year for the Fraud Section

In 2025, Fraud Section prosecutors charged 265 defendants — up 10% compared to 2024 — with aggregate estimated fraud losses exceeding $16 billion, more than double the figure reported in 2024. About one-fourth of this enforcement work was spread throughout three of the four Fraud Section litigation units — the Foreign Corrupt Practices Act Unit (FCPA Unit); the Health and Safety Unit (HSU); and the Market, Government, and Consumer Fraud Unit (MGC Unit).

The FCPA Unit brought three corporate enforcement actions in 2025, “including the Section’s first corporate indictment in fifteen years.” In that ongoing case, United States v. SGO Corporation Limited, the government alleges that various foreign executives and a voting machine corporation conspired to launder more than $1 million in bribes to a Philippine election official through coded language, fraudulent contracts, and international wire transfers to conceal corrupt payments.

The HSU — formed in November 2025 after DOJ absorbed the Consumer Financial Protection Bureau (CFPB)’s criminal portfolio and prosecutors — works closely with the U.S. Food and Drug Administration (FDA) and focuses its enforcement efforts on adulterated, misbranded, or counterfeit food, drugs, and devices; transportation safety; and consumer product defects. In the few months since its formation, the HSU brought four corporate enforcement actions, charging conduct ranging from the sale of adulterated surgical crowns to the forging of FDA approval to market surgical and sterilization devices.

The MGC Unit — previously known as the Market Integrity and Major Frauds Unit — is responsible for prosecuting domestic market manipulation and federal program fraud. In 2025, the MGC Unit focused on fraud that undermined national security, and, as part of a cross-agency “Trade Fraud Task Force,” brought its first cases against individuals and corporations engaging in trade and tariff fraud. Moreover, with an increase of 25 prosecutors from the CFPB, the MGC Unit continued to target defendants who defrauded vulnerable and elderly citizens through Ponzi and pyramid schemes.

Healthcare Fraud as a Central Enforcement Priority

But healthcare fraud dominated the Fraud Section’s docket in 2025. Of the Fraud Section’s 265 indicted defendants, the Health Care Fraud Unit (HCF Unit) brought charges against 194, alleging more than $15 billion in healthcare fraud losses. The HCF Unit also led the largest “Health Care Fraud Takedown” (Takedown) in DOJ history, securing convictions against hundreds of federal and state defendants and seizing over $245 million in cash and other assets.

HHS participated extensively in this 2025 Takedown. As detailed in newly appointed HHS Inspector General T. March Bell’s first Semiannual Report to Congress, the Takedown targeted alleged fraud schemes involving:

1. Wound Care: Medical professionals and other defendants submitted $1.1 billion in allegedly fraudulent Medicare and other healthcare benefit program claims for wound care, allegedly targeting vulnerable elderly patients, many of whom received medically unnecessary wound grafts.

2. Durable Medical Equipment Fraud: Transnational criminal organizations allegedly exploited the stolen identities of more than 1 million Medicare enrollees and healthcare providers and submitted $10.6 billion in allegedly fraudulent Medicare claims for urinary catheters and other durable medical equipment.

3. Diagnostic Testing: Medical professionals submitted $1.84 billion in allegedly false and fraudulent Medicare, Medicaid, and private insurance claims for diagnostic testing, medical visits, and treatments that were alleged to be medically unnecessary, provided in connection with kickbacks and bribes, or never provided at all.

4. Telemedicine: Medical professionals and executives submitted $1.17 billion in allegedly fraudulent Medicare claims resulting from alleged telemedicine and genetic testing fraud schemes.

5. Drug Diversion: Pharmacists and other defendants allegedly illegally diverted more than 15 million pills of prescription opioids and other controlled substances.

In total, the collaboration between HHS-OIG and DOJ — as well as the Federal Bureau of Investigation (FBI) and other state and local law enforcement agencies — is anticipated to recover $14.6 billion through criminal resolutions and seizures. Aside from this cross-agency criminal Takedown, HHS-OIG also reported a renewed emphasis on civil enforcement, noting that its investigations led to nearly 500 False Claims Act cases between April and September 2025.

Both reports highlight the government’s continued, proactive reliance on advanced data analytics to identify and prosecute these fraud schemes. In June 2025, the Fraud Section announced that it is working closely with agency partners, including HHS-OIG and the FBI, to create a Health Care Fraud Data Fusion Center, which will leverage cloud computing, artificial intelligence (AI), and advanced analytics to “revolutionize” how the government detects, investigates, and prosecutes emerging healthcare fraud schemes.

HHS-OIG similarly emphasized that “data analytics” is a key tool to “prevent[] or stop[] fraud schemes before they escalate.” For example, the Semiannual Report touted the use of enhanced data analytics to flag alarming billing trends in the wound care product industry, where Medicare Part B expenditures exceeded $10 billion annually and grew by more than 600% since 2023. These findings closely track the Fraud Section prosecutions alleging billion-dollar amniotic graft and wound care fraud schemes involving kickbacks and medically unnecessary treatments.

Both reports also show how the rise of AI tools and digital health platforms can be exploited to perpetrate fraud. The 2025 Takedown targeted the use of AI to fabricate patient consent and the abuse of telehealth flexibility to fraudulently prescribe medication. HHS-OIG likewise identified a sharp growth in Medicare payments for remote patient monitoring that raises serious program integrity concerns, particularly where providers lack established clinical relationships with beneficiaries.

Another notable throughline in both reports is the government’s growing emphasis on patient harm. The Fraud Section’s Year in Review highlighted prosecutions where fraudulent conduct resulted in unnecessary infusions, adulterated medical products, illegal opioid distribution, and death. Corporate resolutions in 2025 frequently included strict compliance obligations, victim compensation, and independent monitors. HHS-OIG’s Semiannual Report echoes this emphasis. Beyond financial recoveries, HHS-OIG emphasized its role in protecting patients from unsafe or substandard care, including a focus on enforcement actions against abusive nursing home chains and clinicians who falsified diagnoses or records. The convergence of DOJ and HHS-OIG messaging suggests that the government will continue to frame fraud not merely as a financial offense, but as conduct with direct and tangible public health consequences.

Looking to 2026

Taken together, the Fraud Section’s Year in Review and HHS-OIG’s Semiannual Report send a clear signal: healthcare fraud enforcement is intensifying, increasingly data-driven, and highly coordinated across agencies. Providers, payors, life sciences companies, and digital health platforms should expect continued scrutiny of high-growth billing areas, novel technologies, and arrangements that implicate the Anti-Kickback Statute or False Claims Act.

The reports also underscore the importance of robust compliance programs, timely internal investigations, and — where appropriate — voluntary self-disclosure. As DOJ and HHS-OIG continue to expand their analytic capabilities and shift toward early intervention, organizations that fail to identify and remediate issues proactively may face heightened enforcement risk.

For questions about healthcare fraud enforcement, please contact the authors or any member of Arnold & Porter’s White Collar Defense & Investigations or False Claims Act Investigations & Defense practice groups.

* Bryan Borodkin contributed to this Advisory. Bryan is an associate in Arnold & Porter’s New York office.

© Arnold & Porter Kaye Scholer LLP 2026 All Rights Reserved. This Advisory is intended to be a general summary of the law and does not constitute legal advice. You should consult with counsel to determine applicable legal requirements in a specific fact situation.