The Numbers

The 2026 Takedown did not match last year’s record numbers.  But, 455 defendants, including 90 doctors and other licensed medical professionals were charged.  The coordinated enforcement involved a “whole of government” approach which included:

• Actions by the Centers for Medicare and Medicaid Services (CMS) to suspend 1,079 providers and revoke billing privileges for 1,403 providers.
• 48 Civil Monetary Payment settlements amounting to over $73 million, over 1,400 provider exclusions, and 25 actions by the U.S. Department of Health and Human Services, Office of Inspector General (“HHS-OIG”) under the Civil Monetary Penalties Law seeking more than $10 billion in payments to the Medicare Trust Fund from payments that CMS caught and suspended before the funds were paid to the fraudulent providers.
• Civil charges against 13 defendants for $14.8 million in health care fraud schemes, as well as civil settlements with 31 defendants totaling $23 million.
• 928 administrative cases by the Drug Enforcement Administration (DEA) seeking the revocation of authority to handle and/or prescribe controlled substances since October 1, 2025.

Increased “Whole of Government” approach

The government has always used multiple agencies in its efforts to combat fraud.  But the DOJ has now stated they are using “cutting-edge use of data analytics to target the worst actors”. including employing advanced data analytics through its Data Fusion Center. The DOJ is now working to ensure coordination with asset seizure, civil remedies, administrative actions, and payment-policy changes.  As a result, a single health care fraud investigation may now include parallel criminal, civil, administrative, exclusion, payment-suspension, and licensing consequences.  Conaway & Strickler, PC routinely handles licensing and regulatory issues as well as fighting False Claims Act issues at the civil and criminal level.  

Creation of the National Fraud Enforcement Division (“NFED”) 

NFED may be the clearest sign of this whole of government approach.  According to the April, 2026 DOJ memorandum, the NFED’s mission is to “zealously investigate and prosecute” fraud involving taxpayer dollars.  The 2026 Takedown appears to be NFED’s first major public health care fraud press release.

TRENDS: Healthcare Fraud in Allografts

Allografts and skin grafts cases have risen significantly from an emerging issue to front-line enforcement target.

The allograft cases are important to note because they clearly show what a healthcare investigation looks like in 2026.  The DOJ uses their data driven investigatory prowess to detect high reimbursement, aggressive marketing, alleged kickbacks, vulnerable patients, questionable medical necessity, and patient harm. In the press release for 2026, the DOJ charged 11 defendants in schemes involving allografts, and the press release described Medicare payments for allografts rising sharply before CMS adjusted payment rates.  

DOJ’s theory here is like the cancer genetic cases.  Both the allograft and CGx cases show a high payment for the claim which is an area that created an opportunity for fraud, according to the DOJ.  The 2026 Takedown shows how data analysis has moved to the forefront of their investigations. They comb through all the claims, matc it with financial tracing and draw conclusions from there.

Thoughts for Health Care Companies

The 2026 Takedown reinforces that health care fraud enforcement is here to stay. As discussed above, the government investigations are becoming more coordinated, targeted and more focused on the numbers. 

It is important therefore to respond accordingly and be sure all documentation necessary is on hand before any type of inquiry occurs.  

Conaway & Strickler, PC has a deep understanding of these kinds of case.  Sometimes, prompt disclosure and cooperation is the route to take and sometimes combatting the allegations is the route to take. We continue to monitor enforcement actions to remain aware of all of the newest developments.  Contact us for more information or for assistance.