DOJ Continues to Prioritize Medicare Advantage Enforcement with $22.5 Million Settlement
On September 30, 2026, the Department of Justice announced a $22.5 million settlement with a Medicare Advantage (“MA”) plan to resolve allegations that it violated the False Claims Act by failing to withdraw inaccurate diagnosis codes for enrollees and improperly retaining resulting overpayments from Medicare. As previously reported, MA fraud is a top priority for FCA enforcement in this Administration, and the settlement is the latest in a string of recent resolutions we covered here and here.
U.S. Department of Justice Announces Major Justice Manual Revisions on Sub-Regulatory Guidance and Dismissals of FCA Qui Tams
In a move with substantial implications for federal enforcement generally and the False Claims Act (“FCA”) in particular, the U.S. Department of Justice (“the Department”) on September 18, 2026 announced major revisions to two sections of the Justice Manual: (1) Section 1-19.000, which governs the issuance and use of guidance documents; and (2) Section 4-4.111, which governs the Department’s authority to seek dismissal of FCA qui tams. Reverting to the Department’s position in the first Trump Administration, the revisions to Section 1-19.000, as the Department explained, “reinstate[] and build[] upon [the Department]’s 2017 policy that sub-regulatory guidance cannot impose legal obligations beyond those established by statute or regulation.” And the revisions to Section 4-4.111 provide that the Department will evaluate every FCA qui tam for potential dismissal by the Department under 31 U.S.C. section 3730(c)(2)(A). The Department framed the changes as strengthening its fight against fraud through clearer standards that promote fair and effective enforcement.
DOJ Announces Largest Settlement Yet in Drive to Use the FCA to Target Alleged Employment Discrimination
Earlier this week, the Department of Justice (“DOJ”) announced a $25 million settlement with three Accenture entities to resolve allegations that they violated the FCA by engaging in conduct DOJ alleges violated Title VII and Federal Acquisition Regulation (“FAR”) clause 52.222-26. This is the third settlement—we reported on the first two here and here—reached via DOJ’s Civil Rights Fraud Initiative, which aims to use the FCA to address alleged discrimination by employers that have contracted with the federal government. $11,627,000 of the settlement amount was restitution, suggesting a damages multiplier just above two, which is consistent with the prior two settlements.
DOJ Continues Medicare Advantage Enforcement Focus with $541.5 Million Settlement
On August 26, 2026, the Department of Justice announced a $541.5 million settlement with a Florida-based provider group serving beneficiaries in the retirement community to resolve allegations that the group violated the False Claims Act by submitting invalid diagnosis codes as part of the Medicare Advantage (“MA”) program. The settlement is the next in DOJ’s intensified enforcement focus on the MA program, which we have previously covered here and here.
DOJ Announces Second Settlement Resolving FCA Allegations Based on Employment Discrimination
Earlier this week, the Department of Justice (“DOJ”) announced a $21.5 million settlement agreement with five Deloitte entities to resolve allegations that they violated the FCA by engaging in conduct DOJ alleges violated Title VII and Federal Acquisition Regulation (“FAR”) clause 52.222-26. Guided by three still-effective executive orders, on which we have reported here and here, the Trump Administration is using the FCA and a variety of other tools, including the Equal Credit Opportunity Act, in a broad, cross-agency enforcement initiative focused on alleged discrimination and touching companies in every industry.
DOJ’s $5.15 Million FCA Settlement Reinforces Focus on Tariff and Customs Compliance
On August 5, 2026, DOJ announced a $5.15 million settlement with a Taiwanese light-emitting diode (“LED”) manufacturer and its Texas-based subsidiary to resolve allegations under the False Claims Act (“FCA”), the common law, and the Tariff Act of 1930, as amended, that the companies knowingly failed to pay additional tariffs on Chinese-origin LEDs imported into the United States. The claims stem from a qui tam suit filed by a former employee. See United States ex rel. Wang v. Everlight Electronics Co., Ltd., et al., No. TDC-21-cv-1607 (D. Md.). As we reported here and here, this settlement is the latest example of DOJ’s push to target trade fraud through its Trade Fraud Task Force.
$14.1 Million FCA Settlement Underscores Medicare Advantage Coding Scrutiny
On August 3, 2026, DOJ announced a $14.1 million settlement with a management services organization (“MSO”) for primary care groups to resolve allegations that the organization violated the False Claims Act by causing inaccurate diagnosis codes to be submitted to the Medicare Advantage (“MA”) program. The allegations were included in a qui tam suit filed by a whistleblower who worked for two Medicare Advantage Organizations (“MAOs”). See United States ex rel. Karen Bowers v. Complete Health Partners, Inc., Pharos Capital Group, LLC, Viva Health Inc., and BlueCross and Blue Shield of Alabama, No. 3:22-cv-463 (M.D. Fla.). This is the latest in a string of MA-related FCA resolutions; alleged fraud on the MA program continues to be a top area of focus for DOJ, as we previously reported here.
Laboratory, Owners, and Investors Settle COVID-19 Testing Fraud Allegations for $24 Million
On July 23, 2026, the Department of Justice announced that clinical lab Magnolia Diagnostics and its owners agreed to pay $19.2 million to resolve allegations that they violated the False Claims Act by billing Medicare for medically unnecessary respiratory pathogen panel (“RPP”) testing performed in connection with COVID-19 testing at senior living communities. Notably, Magnolia’s investors separately agreed to pay an additional $4.8 million to resolve alleged common law claims for unjust enrichment and payment by mistake and claims under the Federal Debt Collection Procedures Act arising from distributions they received from the laboratory. Assistant Attorney General Brett Shumate emphasized that the Department will seek to hold accountable not only entities that submit false claims, but also individuals and investors who allegedly benefit from fraudulent conduct, which is consistent with previous statements of DOJ’s enforcement priorities and resolutions, as we covered here and here.
DOJ Releases FOCUS Questionnaire to Assist in Evaluating Qui Tams Filed by Data Miners
As we previously reported here, the Department of Justice has launched its Fraud Oversight through Careful Use of Statistics (“FOCUS”) initiative. The initiative gives data miners an opportunity to meet with the Civil Fraud Section to “explain what differentiates their approach, how they validate their findings, and why their methodology provides a reliable basis for identifying high-quality, actionable False Claims Act matters.” (more…)
June DOJ/SBA FCA Settlement Highlights Continued Focus on Contractor Compliance
On June 9, 2026, DOJ announced a settlement with Broadway Electric Inc. (“Broadway”); its subsidiary, Cornerstone Contracting Inc. (“Cornerstone”); and two of their individual executives, for $21.3 million to resolve False Claims Act allegations. The settlement targeted alleged fraud against the Small Business Administration’s (“SBA”) set-aside contract program for service-disabled veteran-owned small businesses (“SDVOSBs”). The settlement suggests that the government is surging resources to both anti-fraud issues generally, and to alleged SBA fraud in particular. (more…)
