DOJ and HHS Launch Joint Health Care Fraud Policy
The federal agencies established a unified voluntary self-disclosure policy for suspected criminal health care fraud.
Updated on Oct. 20, 2026 in Healthcare
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The U.S. Department of Justice and the HHS Office of Inspector General have launched a joint voluntary self-disclosure policy to streamline how health care fraud is reported. Companies can now receive benefits under both agencies' protocols by disclosing potential criminal conduct directly to the DOJ's Health Care Fraud Section.
Why it matters
The agencies aimed to align and streamline their previously separate approaches to voluntary self-disclosures of criminal health care fraud. This change clarifies how organizations can qualify for a declination under the DOJ Corporate Enforcement Policy while meeting HHS-OIG requirements.
The new framework establishes a formal process for voluntary self-disclosures that applies to all potential criminal health care fraud. The policy does not reduce investigative requirements for either agency's enforcement programs.
The players
Department of Justice
The United States Department of Justice is a federal executive department responsible for the enforcement of federal laws and the administration of justice.
Department of Health and Human Services Office of Inspector General
The HHS Office of Inspector General is a federal oversight agency that protects the integrity of HHS programs and the health and welfare of the beneficiaries.
The details
Companies are now encouraged to report suspected criminal conduct directly to the DOJ to obtain unified policy benefits, as disclosures made solely to the HHS-OIG generally do not qualify for a declination. Conduct restricted to violations of the physician self-referral law remains outside the scope of the updated HHS-OIG Protocol.
Timeline
The DOJ and HHS-OIG announced the joint disclosure policy on October 15, 2026.
Market Landscape
This policy update integrates agency procedures with the DOJ Corporate Enforcement Policy to provide a standardized path for corporate compliance. It represents an ongoing trend toward harmonizing federal oversight in the healthcare industry to reduce regulatory ambiguity.
Health care organizations should review their internal reporting structures to ensure potential criminal fraud disclosures are routed to the appropriate DOJ channels. Failing to disclose directly to the DOJ may disqualify companies from specific declination benefits.
The takeaway
Organizations should perform thorough internal investigations and identify all involved individuals to meet the requirements for potential leniency. Coordinating disclosures between these two federal agencies is now essential for companies seeking to resolve fraud allegations effectively.
Further reading
For additional context, visit the Healthcare section.
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Should the government offer legal leniency to companies that voluntarily report their own criminal misconduct?
