HHS, DOJ Launch False Claims Act Self-Disclosure Pilot Program

In a marathon week of program integrity-related announcements, the Department of Health and Human Services (HHS) and the Department of Justice (DOJ) launched a six-month Healthcare False Claims Act Self-Disclosure Pilot Program (FCA SDPP) on October 22, 2026. According to the FCA SDPP protocol, this program would offer a clear and predictable pathway for companies seeking to obtain a coordinated resolution of civil liability under the False Claims Act (FCA) and HHS regulations governing the revocation of Medicare enrollment, permissive exclusion for false or improper claims, and permissive exclusion based on fraud and kickbacks or other prohibited activities.

To participate, eligible companies, including healthcare providers, must voluntarily disclose their potential violations, specify remedial measures or other corrective action, and provide financial information that would be used to calculate the Base Self-Disclosure Repayment, to which a multiplier of 1.25-1.6 will be applied. In exchange, they will receive a release from DOJ under the FCA for the disclosed FCA violation, and HHS Office of Inspector General (OIG) will not require a Corporate Integrity Agreement as part of any resolution of HHS OIG's exclusion authorities under the FCA SDPP. The Centers for Medicare and Medicaid Services also may not impose civil monetary penalties or seek revocation as part of any resolution under the FCA SDPP. The deadline for self-disclosures is April 22, 2027.

LeadingAge will continue to monitor this latest effort, among others, by the federal government to encourage the disclosure of potential violations in its efforts to fight health care fraud.