DOJ Announces Record-Breaking 2026 Health Care Fraud Takedown

On June 23, 2026, the Department of Justice (DOJ) announced the results of its 2026 National Health Care Fraud Takedown (Takedown), charging 455 defendants — including 90 physicians and other licensed medical professionals — in schemes involving more than $6.5 billion in alleged fraud that DOJ says caused significant harm, including death. The cases span 56 federal districts across 45 U.S. states and territories and involve conduct affecting Medicare, Medicaid, and private insurers.

The Takedown is the largest coordinated health care fraud enforcement action in DOJ’s history and reflects several significant enforcement trends. In addition to increased state participation — 50 state Medicaid Fraud Control Units (MFCUs), the most in Department history — the Takedown highlights DOJ’s increasing focus on Medicaid fraud, aggressive pursuit of executives and corporate actors, expanded international cooperation, and greater reliance on data analytics and artificial intelligence to identify potential fraud schemes.

The National Health Care Fraud Takedown

The National Health Care Fraud Takedown is an annual enforcement initiative led by DOJ’s Health Care Fraud Unit in partnership with U.S. Attorneys’ Offices, the Department of Health and Human Services Office of Inspector General (HHS-OIG), the Federal Bureau of Investigation (FBI), the Drug Enforcement Administration (DEA), and state MFCUs. Since its inception in 2007, the initiative has resulted in charges against more than 6,200 defendants accused of submitting over $45 billion in fraudulent claims.

This year’s enforcement effort extended well beyond criminal prosecutions. DOJ announced civil False Claims Act (FCA) settlements totaling over $73 million and FCA liability for 13 defendants totaling $14.8 million. The Takedown included significant administrative sanctions: CMS suspended 1,079 providers, revoked billing privileges for 1,403 providers, and stopped $10 billion in payments; HHS-OIG excluded over 1,400 providers and announced 48 Civil Monetary Penalty settlements totaling over $73 million; the DEA initiated 928 administrative actions seeking to revoke authority to handle or prescribe controlled substances. The government seized more than $182 million in cash, luxury vehicles, jewelry, and other assets.

Wound Care Fraud Remains a Major Enforcement Priority

One of the most significant categories of cases involved amniotic wound allografts — products derived from placental tissue that are used to treat chronic wounds. DOJ charged 11 defendants in six federal districts in connection with schemes involving allegedly unnecessary wound care treatments and improper billing practices.

The government alleged that providers applied medically unnecessary wound care products, used products in quantities exceeding clinical need, or paid and received illegal kickbacks tied to product use. For example, DOJ charged the vice president of sales at a wound care distribution company in a nationwide kickback scheme in which providers billed Medicare over $4 billion for the company’s allografts, resulting in over $2 billion in payments. The executive allegedly received over $24 million in proceeds. In a separate case, a nurse practitioner was charged in connection with an alleged $906 million scheme involving medically unnecessary allograft applications, billing Medicare, on average, more than $1 million per patient. The nurse allegedly targeted terminally ill patients and billed for treatments unlikely to provide clinical benefit.

These prosecutions, among many others announced in the Takedown, reflect DOJ’s increasing willingness to pursue not only treating providers, but also executives and other individuals involved in the business and distribution side of health care fraud schemes.

Medicaid Fraud Enforcement Expands

According to DOJ, the Takedown also marked the largest Medicaid fraud enforcement action in its history, both in defendants charged and alleged losses. DOJ charged 295 defendants in schemes involving more than $518 million in alleged false Medicaid claims.

Representative examples include allegations that providers billed Medicaid for services never rendered, paid kickbacks to recruit beneficiaries, and billed for medically unnecessary treatments and medications.

The significant number of Medicaid-related charges underscores DOJ’s recently heightened focus on Medicaid fraud, supported by the Acting Attorney General’s authorization allowing Health Care Fraud Units to investigate Medicaid fraud nationwide.

Patient Harm

DOJ emphasized that health care fraud is not a purely financial crime, highlighting cases in which patients were allegedly harmed. In one case, the medical director of a cardiovascular testing practice was charged in connection with an $89 million scheme to conduct unnecessary cardiac testing on student athletes. The defendant allegedly approved abnormal test results as normal — one set in roughly 11 seconds — and a student athlete with an undetected enlarged heart later died during basketball practice. In another case, defendants allegedly operated an opioid refill line that dispensed Schedule II prescriptions without patient interaction; some patients who obtained drugs through it suffered fatal overdoses.

International Fraud Schemes and Fugitive Enforcement

This year’s Takedown also highlights DOJ’s increasing focus on transnational health care fraud. Several defendants were charged in connection with a criminal organization allegedly responsible for billions of dollars in fraudulent durable medical equipment claims submitted to Medicare. DOJ announced that key members were apprehended overseas — including one defendant taken into custody in Kyrenia in a case involving an additional $3.7 billion in alleged false claims, and two others extradited from Estonia.

The government also highlighted early successes from the FBI’s newly launched Most Wanted Health Care Fraudsters initiative, including the apprehension in the Philippines of a fugitive in a $1.2 billion telemedicine scheme just four days after his addition to the list. DOJ announced two new additions to the list in connection with the Takedown.

Data Analytics and AI Continue to Transform Enforcement

Perhaps the most important long-term development reflected in this year’s Takedown is DOJ’s growing use of data analytics and artificial intelligence. The Health Care Fraud Unit’s Data Fusion Center played a significant role in identifying several schemes announced this year, including suspicious wound care billing patterns. The Department also announced new agreements with CMS, the Department of Homeland Security, and the Federal Trade Commission that will expand data-sharing capabilities and support advanced analytics in fraud investigations.

The first prosecution arising from the Health Care Fraud Unit’s Financial Intelligence Review Team involved an alleged $67 million scheme to bill Illinois Medicaid for behavioral health services never provided. According to DOJ, the defendant submitted claims for more than 500 hours of counseling and therapy services per day, far exceeding the company’s provider capacity. Investigators also identified instances in which patients were hospitalized elsewhere on dates when behavioral health services were supposedly rendered. The investigation opened within days of the financial intelligence review, and the defendant was arrested less than seven months later while allegedly attempting to leave the country.

Implications for Providers, Insurers, and Compliance Professionals

The 2026 National Health Care Fraud Takedown reflects several significant enforcement trends: DOJ’s increased use of data analytics in criminal investigations, expanded coordination among federal and state enforcement partners, heightened focus on Medicaid fraud, growing scrutiny of health care executives and other corporate actors, emphasis on cases involving patient harm, and continued efforts to combat transnational health care fraud schemes. Together, these developments suggest that sophisticated AI-enabled criminal investigations, broad interagency collaboration, and international enforcement efforts play an increasingly important role in the government’s approach to identifying and prosecuting health care fraud.

For health care providers, insurers, and compliance professionals, the Takedown underscores the importance of achieving compliance programs capable of identifying unusual billing patterns and other anomalies before investigators do. For questions about the Takedown or its implications, please contact the authors or any member of Arnold & Porter’s White Collar Defense & Investigations or Life Sciences & Healthcare Regulatory practice groups.

© Arnold & Porter Kaye Scholer LLP 2026 All Rights Reserved. This Blog post 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.