New Joint Policy for Health Care Fraud Disclosures

Healthcare operators must now report potential criminal conduct directly to the DOJ to access unified enforcement benefits.

Updated on Oct. 20, 2026 in Healthcare

Bold flat-color editorial illustration of a single monolithic stone plinth, representing the new unified policy for healthcare fraud disclosures. — The DOJ and HHS have launched a unified voluntary self-disclosure policy to standardize how healthcare operators report potential criminal health care fraud. AI Illustration. Upload story photo >

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The U.S. Department of Justice (DOJ) and the HHS Office of Inspector General (HHS-OIG) have established a joint voluntary self-disclosure policy for potential criminal health care fraud. The move standardizes reporting channels for healthcare operators seeking to qualify for enforcement benefits from both agencies.

Why it matters

The policy aims to eliminate the previous ambiguity operators faced when navigating separate agency disclosure protocols, which often created inconsistent outcomes for companies reporting criminal conduct. Aligning these programs clarifies the threshold for qualifying for a declination under the DOJ Corporate Enforcement Policy.

The new joint policy creates a singular, unified pathway for voluntary criminal fraud disclosures to the DOJ and HHS-OIG. It leaves the existing investigative requirements for both agencies unchanged while providing clarity on which reports qualify for DOJ Corporate Enforcement Policy benefits.

The players

U.S. Department of Justice

The federal executive department responsible for the enforcement of federal laws, including the investigation and prosecution of criminal health care fraud.

HHS Office of Inspector General

The independent oversight body within the Department of Health and Human Services that monitors waste, fraud, and abuse in federal healthcare programs.

The details

Under the new policy, healthcare companies must now report potential criminal conduct directly to the DOJ's Health Care Fraud Section to secure joint benefits. Disclosures submitted exclusively to the HHS-OIG will generally no longer qualify for a declination under the DOJ Corporate Enforcement Policy. Companies must continue to conduct thorough internal investigations and identify all involved individuals to meet the compliance standards set by both agencies.

October 15, 2026: The DOJ and HHS-OIG jointly announced the new self-disclosure policy.

Market Landscape

This policy change marks an evolution in how federal agencies apply the DOJ Corporate Enforcement Policy to the healthcare sector. It formally bridges the enforcement priorities of the DOJ and the HHS-OIG to address gaps that previously allowed for inconsistent disclosure outcomes.

Operators must update their internal compliance protocols to mandate direct reporting to the DOJ for any suspected criminal conduct to ensure eligibility for unified enforcement benefits. Counsel should be consulted to ensure that current self-disclosure practices align with these new administrative requirements.

The takeaway

The joint policy eliminates the uncertainty of previous dual-reporting requirements for criminal health care fraud. Operators should audit existing compliance manuals to ensure all potential criminal conduct is routed to the DOJ's Health Care Fraud Section to maintain eligibility for agency declination.