In a significant decision for healthcare providers, the Texas Supreme Court reversed a court of appeals decision that had revived claims against a laboratory testing company and reinstated summary judgment for the defendant. The Court held that the Texas Health Care Program Fraud Prevention Act’s (the “Act”) omissions provision requires proof of materiality, even though the provision does not expressly use the word “material.” (more…)
The Texas Attorney General (“Texas AG”) recently announced a settlement with AstraZeneca Pharmaceuticals LP (“AstraZeneca”) for $33,998,000 to resolve allegations under the Texas Health Care Program Fraud Prevention Act (“THFPA”) arising from the company’s nurse educator program and nurse and patient support programs. SeeState ex rel. SCEF, LLC v. AstraZeneca Pharmaceuticals LP, No. D-1-GN-25-011002 (250th Dist. Ct., Travis County, transferred Dec. 18, 2025). This settlement is the latest in a series of actions by the Texas AG that demonstrate the office’s focus on large healthcare corporations and aggressive deployment of the THFPA, as discussed here. (more…)
The Administration has taken another significant step in its effort to increase pressure on state Medicaid Fraud Control Units (“MFCUs”). On July 2, 2026, the United States Attorney’s Office for the Northern District of New York announced the U.S. Department of Health and Human Services Office of Inspector General (“HHS-OIG”) denied recertification of New York’s MFCU and suspended its federal funding effective July 1. The decision follows the Administration’s announcements earlier this year that it would closely scrutinize state MFCU performance, including through funding consequences for states perceived as failing to aggressively investigate and prosecute Medicaid fraud, which we previously covered here. (more…)
https://fcablog.sidley.com/wp-content/uploads/sites/5/2022/08/sidleyLogo-e1643922598198.png00Jaime L.M. Joneshttps://fcablog.sidley.com/wp-content/uploads/sites/5/2022/08/sidleyLogo-e1643922598198.pngJaime L.M. Jones2026-07-06 12:16:362026-07-06 12:16:36HHS-OIG Decertifies New York Medicaid Fraud Control Unit, Escalating Federal Scrutiny of State Medicaid Fraud Enforcement
On June 24, 2026, the Investigations and Oversight Subcommittee of the U.S. House of Representatives Committee on Science, Space, and Technology held a hearing on “Federal Research Funds: The False Claims Act’s Role in Combating Grant Fraud.” Brenna Jenny, DOJ’s Deputy Assistant Attorney General for Commercial Litigation, testified on three FCA enforcement “focus areas” related to federal grants, before responding to questions regarding the use of the statute to target discrimination.
https://fcablog.sidley.com/wp-content/uploads/sites/5/2022/08/sidleyLogo-e1643922598198.png00Kristin Graham Koehlerhttps://fcablog.sidley.com/wp-content/uploads/sites/5/2022/08/sidleyLogo-e1643922598198.pngKristin Graham Koehler2026-06-29 09:09:382026-06-26 18:15:29In House Hearing, DAAG Jenny Discusses FCA Enforcement Priorities Related to Grants, Faces Questioning on Using FCA to Target Discrimination
On June 18, 2026, DOJ announced a settlement with LOGZONE Inc., a defense contractor, to pay $507,144 to resolve allegations that it violated the False Claims Act through its failure to satisfy cybersecurity requirements in its contracts with the Department of the Navy (“the Navy”). This settlement involves yet another coordinated enforcement effort through the recently created Task Force to Eliminate Fraud, previously reported on here and here. DOJ reached this settlement with assistance from the Department of the Navy, the Department of the Army, and the Defense Contract Management Agency (“DCMA”). This settlement underscores cybersecurity compliance as a focus of FCA enforcement.
https://fcablog.sidley.com/wp-content/uploads/sites/5/2022/08/sidleyLogo-e1643922598198.png00Kristin Graham Koehlerhttps://fcablog.sidley.com/wp-content/uploads/sites/5/2022/08/sidleyLogo-e1643922598198.pngKristin Graham Koehler2026-06-23 12:19:332026-06-23 12:19:33DOJ Reaches $507,144 Settlement with Defense Contractor, Signals Increased FCA Scrutiny of Cybersecurity Self-Assessments
On June 10, 2026, nineteen states and the District of Columbia filed an Administration Procedure Act suit challenging President Trump’s Executive Order No. 14398 (the EO), on which we have previously reported here. The EO advances the Trump Administration’s goal to eradicate diversity, equity, and inclusion (DEI) activities among federal contractors by, among other things, expressly tethering DEI to potential FCA liability. Targeting the EO’s language on FCA liability, the plaintiff states argue that it contravenes the materiality test established by the Supreme Court in Escobar.
https://fcablog.sidley.com/wp-content/uploads/sites/5/2022/08/sidleyLogo-e1643922598198.png00Kristin Graham Koehlerhttps://fcablog.sidley.com/wp-content/uploads/sites/5/2022/08/sidleyLogo-e1643922598198.pngKristin Graham Koehler2026-06-15 11:34:142026-06-15 11:35:20Challenging Executive Order on DEI, States Say It Gets FCA Materiality Wrong
It is not business as usual at DOJ. In the latest announcement related to the Department’s efforts to fight alleged fraud, on May 27, 2026, Assistant Attorney General Brett Shumate issued a memorandum directing DOJ’s Civil Division and U.S. Attorneys’ Offices to accelerate the review of qui tams alleging fraud against federally funded state-administered benefits programs, including programs involving housing, food assistance, medical care, and cash assistance. The memorandum, titled “Accelerating Review and Enhancing Enforcement in Benefits Fraud Matters,” implements President Trump’s March 2026 Executive Order establishing the “Task Force to Eliminate Fraud,” which we reported on here, and which directed the Department to take appropriate action to promote “meritorious” qui tams and to complete investigations sooner, including within the 60-day statutory period.
https://fcablog.sidley.com/wp-content/uploads/sites/5/2022/08/sidleyLogo-e1643922598198.png00Kristin Graham Koehlerhttps://fcablog.sidley.com/wp-content/uploads/sites/5/2022/08/sidleyLogo-e1643922598198.pngKristin Graham Koehler2026-05-28 09:10:032026-05-28 09:10:03DOJ Announces Accelerated Review of FCA Qui Tams Alleging Fraud Against State-Administered Benefits Programs
On May 15, 2026, the U.S. Department of Justice (“DOJ”) and Texas Attorney General Ken Paxton announced agreements with Texas Children’s Hospital (“TCH”) resolving allegations related to TCH’s provision of gender-affirming care to minors. The matter marks the first publicly announced resolution arising from DOJ’s ongoing nationwide investigation into alleged federal-law violations associated with such care. The resolution is notable not only because of the subject matter involved, but also because of the enforcement architecture it reflects: coordination between DOJ and a state attorney general; reliance on False Claims Act (“FCA”) and Federal Food, Drug, and Cosmetic Act (“FDCA”) theories that remain largely untested in this context; and remedies that extend well beyond a monetary payment.
https://fcablog.sidley.com/wp-content/uploads/sites/5/2022/08/sidleyLogo-e1643922598198.png00Doreen M. Rachalhttps://fcablog.sidley.com/wp-content/uploads/sites/5/2022/08/sidleyLogo-e1643922598198.pngDoreen M. Rachal2026-05-26 12:31:002026-05-26 13:53:49DOJ and Texas AG Announce First Settlement in National Investigation of Gender-Affirming Care for Minors
Texas Supreme Court Imposes Materiality Requirement on Texas Healthcare Fraud Omissions Claims
In a significant decision for healthcare providers, the Texas Supreme Court reversed a court of appeals decision that had revived claims against a laboratory testing company and reinstated summary judgment for the defendant. The Court held that the Texas Health Care Program Fraud Prevention Act’s (the “Act”) omissions provision requires proof of materiality, even though the provision does not expressly use the word “material.” (more…)
Kwaku A. Akowuah
Washington, D.C.
kakowuah@sidley.com
Scott D. Stein
Chicago
sstein@sidley.com
Jaime L.M. Jones
Chicago
jaime.jones@sidley.com
Kenneth G. Coffin
Dallas
kenneth.coffin@sidley.com
Matt Bergs
Chicago
mbergs@sidley.com
Texas AG Secures Nearly $34 Million Settlement with Pharmaceutical Company, Reinforcing Active Ongoing THFPA Enforcement
The Texas Attorney General (“Texas AG”) recently announced a settlement with AstraZeneca Pharmaceuticals LP (“AstraZeneca”) for $33,998,000 to resolve allegations under the Texas Health Care Program Fraud Prevention Act (“THFPA”) arising from the company’s nurse educator program and nurse and patient support programs. See State ex rel. SCEF, LLC v. AstraZeneca Pharmaceuticals LP, No. D-1-GN-25-011002 (250th Dist. Ct., Travis County, transferred Dec. 18, 2025). This settlement is the latest in a series of actions by the Texas AG that demonstrate the office’s focus on large healthcare corporations and aggressive deployment of the THFPA, as discussed here. (more…)
Jaime L.M. Jones
Chicago
jaime.jones@sidley.com
Kenneth G. Coffin
Dallas
kenneth.coffin@sidley.com
Matt Bergs
Chicago
mbergs@sidley.com
Anna M. Schmitt
Chicago
anna.schmitt@sidley.com
HHS-OIG Decertifies New York Medicaid Fraud Control Unit, Escalating Federal Scrutiny of State Medicaid Fraud Enforcement
The Administration has taken another significant step in its effort to increase pressure on state Medicaid Fraud Control Units (“MFCUs”). On July 2, 2026, the United States Attorney’s Office for the Northern District of New York announced the U.S. Department of Health and Human Services Office of Inspector General (“HHS-OIG”) denied recertification of New York’s MFCU and suspended its federal funding effective July 1. The decision follows the Administration’s announcements earlier this year that it would closely scrutinize state MFCU performance, including through funding consequences for states perceived as failing to aggressively investigate and prosecute Medicaid fraud, which we previously covered here. (more…)
Jaime L.M. Jones
Chicago
jaime.jones@sidley.com
Lisa H. Miller
Washington, D.C.
lisa.miller@sidley.com
Kenneth G. Coffin
Dallas
kenneth.coffin@sidley.com
Lauren E. McBride
Chicago
lmcbride@sidley.com
In House Hearing, DAAG Jenny Discusses FCA Enforcement Priorities Related to Grants, Faces Questioning on Using FCA to Target Discrimination
On June 24, 2026, the Investigations and Oversight Subcommittee of the U.S. House of Representatives Committee on Science, Space, and Technology held a hearing on “Federal Research Funds: The False Claims Act’s Role in Combating Grant Fraud.” Brenna Jenny, DOJ’s Deputy Assistant Attorney General for Commercial Litigation, testified on three FCA enforcement “focus areas” related to federal grants, before responding to questions regarding the use of the statute to target discrimination.
(more…)
Kristin Graham Koehler
Washington, D.C.
kkoehler@sidley.com
Jaime L.M. Jones
Chicago
jaime.jones@sidley.com
H. Boyd Greene IV
Washington, D.C.
bgreene@sidley.com
Kyle J. Fiet
Washington, D.C.
kfiet@sidley.com
Joseph R. LoCascio
Chicago
joseph.locascio@sidley.com
DOJ Reaches $507,144 Settlement with Defense Contractor, Signals Increased FCA Scrutiny of Cybersecurity Self-Assessments
On June 18, 2026, DOJ announced a settlement with LOGZONE Inc., a defense contractor, to pay $507,144 to resolve allegations that it violated the False Claims Act through its failure to satisfy cybersecurity requirements in its contracts with the Department of the Navy (“the Navy”). This settlement involves yet another coordinated enforcement effort through the recently created Task Force to Eliminate Fraud, previously reported on here and here. DOJ reached this settlement with assistance from the Department of the Navy, the Department of the Army, and the Defense Contract Management Agency (“DCMA”). This settlement underscores cybersecurity compliance as a focus of FCA enforcement.
(more…)
Kristin Graham Koehler
Washington, D.C.
kkoehler@sidley.com
Jaime L.M. Jones
Chicago
jaime.jones@sidley.com
H. Boyd Greene IV
Washington, D.C.
bgreene@sidley.com
Kenneth G. Coffin
Dallas
kenneth.coffin@sidley.com
David Lashway
Washington D.C.
dlashway@sidley.com
Anna M. Schmitt
Chicago
anna.schmitt@sidley.com
Challenging Executive Order on DEI, States Say It Gets FCA Materiality Wrong
On June 10, 2026, nineteen states and the District of Columbia filed an Administration Procedure Act suit challenging President Trump’s Executive Order No. 14398 (the EO), on which we have previously reported here. The EO advances the Trump Administration’s goal to eradicate diversity, equity, and inclusion (DEI) activities among federal contractors by, among other things, expressly tethering DEI to potential FCA liability. Targeting the EO’s language on FCA liability, the plaintiff states argue that it contravenes the materiality test established by the Supreme Court in Escobar.
(more…)
Kristin Graham Koehler
Washington, D.C.
kkoehler@sidley.com
Jaime L.M. Jones
Chicago
jaime.jones@sidley.com
Scott D. Stein
Chicago
sstein@sidley.com
H. Boyd Greene IV
Washington, D.C.
bgreene@sidley.com
Kyle J. Fiet
Washington, D.C.
kfiet@sidley.com
Joseph R. LoCascio
Chicago
joseph.locascio@sidley.com
DOJ Announces Accelerated Review of FCA Qui Tams Alleging Fraud Against State-Administered Benefits Programs
It is not business as usual at DOJ. In the latest announcement related to the Department’s efforts to fight alleged fraud, on May 27, 2026, Assistant Attorney General Brett Shumate issued a memorandum directing DOJ’s Civil Division and U.S. Attorneys’ Offices to accelerate the review of qui tams alleging fraud against federally funded state-administered benefits programs, including programs involving housing, food assistance, medical care, and cash assistance. The memorandum, titled “Accelerating Review and Enhancing Enforcement in Benefits Fraud Matters,” implements President Trump’s March 2026 Executive Order establishing the “Task Force to Eliminate Fraud,” which we reported on here, and which directed the Department to take appropriate action to promote “meritorious” qui tams and to complete investigations sooner, including within the 60-day statutory period.
(more…)
Kristin Graham Koehler
Washington, D.C.
kkoehler@sidley.com
Jaime L.M. Jones
Chicago
jaime.jones@sidley.com
Lisa H. Miller
Washington, D.C.
lisa.miller@sidley.com
Kenneth G. Coffin
Dallas
kenneth.coffin@sidley.com
DOJ and Texas AG Announce First Settlement in National Investigation of Gender-Affirming Care for Minors
On May 15, 2026, the U.S. Department of Justice (“DOJ”) and Texas Attorney General Ken Paxton announced agreements with Texas Children’s Hospital (“TCH”) resolving allegations related to TCH’s provision of gender-affirming care to minors. The matter marks the first publicly announced resolution arising from DOJ’s ongoing nationwide investigation into alleged federal-law violations associated with such care. The resolution is notable not only because of the subject matter involved, but also because of the enforcement architecture it reflects: coordination between DOJ and a state attorney general; reliance on False Claims Act (“FCA”) and Federal Food, Drug, and Cosmetic Act (“FDCA”) theories that remain largely untested in this context; and remedies that extend well beyond a monetary payment.
(more…)
Doreen M. Rachal
New York, Boston
drachal@sidley.com
Shu Min Ho
Singapore
shumin.ho@sidley.com
Kenneth G. Coffin
Dallas
kenneth.coffin@sidley.com
Lucia Radder Quick
New York
lradderquick@sidley.com
Nicole A. Heise
Chicago
nheise@sidley.com
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