DOJ and HHS Launch Healthcare False Claims Act Self-Disclosure Pilot Program

DOJ and HHS Launch Healthcare False Claims Act Self-Disclosure Pilot Program

On October 22, the US Department of Justice (DOJ) Civil Division and the US Department of Health and Human Services (HHS) announced a six-month Healthcare False Claims Act Self-Disclosure Pilot Program (FCA SDPP). The pilot program offers health care companies a structured path to resolve potential civil FCA violations by coming forward voluntarily, allowing the government to focus its enforcement resources on companies that do not. 

Companies that participate in the pilot program will “receiv[e] favorable treatment from DOJ Civil Division and HHS in a coordinated civil release, with no factual admissions.” Specifically, the DOJ Civil Division will provide a release from civil liability for the disclosed potential FCA violations, HHS will not require a Corporate Integrity Agreement, and the Centers for Medicare & Medicaid Services will not impose civil monetary penalties or seek a revocation of enrollment in the Medicare program. The required repayment will use a multiplier between 1.25 and 1.6, which could be more favorable than the multiplier otherwise applied, and will be set by the DOJ based on various factors, including the promptness of the self-disclosure, the duration and scope of the misconduct, whether senior leadership was involved, the financial benefit to the company, and, where the company has successor liability for the misconduct, whether it promptly remediated it. 

To qualify for the pilot program, a company’s disclosure must (1) “describe all relevant details” about a potential FCA violation unknown to the federal government (though other benefits of self-disclosure and cooperation may still be available if the government is already aware of the conduct), (2) attach documents sufficient to show how the conduct operated, (3) describe its remedial steps, (4) provide sufficient financial information so that the government can calculate repayment, (5) include a certification from an authorized representative that to the best of their knowledge, the submission is truthful and complete, and (6) include contact details for follow-up questions.  The pilot program is temporary, and submissions are accepted through April 22, 2027.

The FCA SDPP was announced within days of two other recent DOJ initiatives designed to promote self-disclosure and reporting: the Fraud Division’s directive outlining a “comprehensive approach” to fraud enforcement, which we covered here in our October 19 post, and the new fraud whistleblower incentive program, which we covered here in our October 26 post. Taken together, these three initiatives underscore the Administration’s emphasis on self-disclosure and reporting as a central part of its fraud enforcement strategy.

Read the DOJ’s press release here and the pilot program itself here.

DOJ Enters First ‘Near Miss’ Non-Prosecution Agreement Under Its Corporate Enforcement Policy

On October 27, the DOJ National Security Division (NSD) and the US Attorney’s Office for the Eastern District of North Carolina announced a non-prosecution agreement (NPA) with Extreme Networks, Inc., a networking company headquartered in Morrisville, North Carolina. It is the first “near miss” NPA under the DOJ’s 2026 Corporate Enforcement and Voluntary Self-Disclosure Policy, meaning the company fully cooperated and remediated but did not qualify for a declination of prosecution. We covered this new policy here.

From approximately March 2018 to March 2022, the company’s then-Russia-based subsidiary filled 11 purchase orders for equipment and services for a Russian producer of air defense systems. That Russian producer was owned by an entity on the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) sanctions list. Local employees hid the customer’s identity from the company’s global trade compliance group, resulting in false export filings and the smuggling of goods from the United States. The company disclosed the conduct to NSD only after it learned of an imminent threat of disclosure by a news publication, which made the disclosure untimely under the Corporate Enforcement and Voluntary Self-Disclosure Policy. Nevertheless, the DOJ noted that Extreme Networks remediated the misconduct and fully cooperated with the investigation, including by providing relevant facts and documents and making employees available for interviews.

The company agreed to forfeit $487,860.92 in proceeds and pay the same amount in a criminal fine, totaling $975,721.84 in criminal penalties. Extreme Networks also agreed to resolve a parallel OFAC administrative matter.

Read the DOJ’s press release here.

Ukrainian National Sentenced to 70 Months for Ransomware Attacks on Hospitals and Businesses

On October 27, the DOJ announced that after pleading guilty in December 2025 to two counts of conspiracy to commit fraud, extortion, and related activity, Artem Stryzhak, a Ukrainian national formerly living in Barcelona, Spain, and extradited to the United States, was sentenced to 70 months in prison for his role in ransomware conspiracies that targeted hospitals, government entities, law firms, and other businesses in the United States and abroad and caused more than $100 million in losses.

According to court documents, Stryzhak became an affiliate of the Nefilim ransomware group in approximately June 2021, and he agreed to give 20% of any ransom he extracted to the group’s administrators, including Volodymyr Tymoshchuk, in exchange for access to the malware. The US Department of State is offering a reward of up to $11 million for information on Tymoshchuk, who remains at large. 

According to court documents in a separate case against Stryzhak, he became one of the earliest affiliates of the Hive ransomware group, which attacked about 1,500 victims worldwide between June 2021 and January 2023, and Stryzhak and his Hive co-conspirators targeted seven victims, including law firms, a dental office, and a health care provider. 

Read the DOJ’s press release here.

The cases are United States v. Stryzhak, No. 1:23-CR-00324 (Nefilim), and United States v. Stryzhak, No. 1:25-CR-00381 (Hive), in the US District Court for the Eastern District of New York. The Hive case was transferred from the Middle District of Florida (No. 6:24-CR-00171-CEM-LHP) under Federal Rule of Criminal Procedure 20.

Telemedicine Company Owner Sentenced to 20 Years for $46 Million Medicare Fraud Scheme

On October 23, the DOJ announced that Christopher Harwood of Fort Lauderdale, Florida, owner of the telemedicine company TelevisitMD, was sentenced to 20 years in prison for leading a Medicare fraud conspiracy that lasted more than six years. The court also ordered Harwood to pay $17,942,402 in restitution to Medicare and to forfeit $10,431,463. Harwood pleaded guilty in March to conspiracy to commit health care fraud and wire fraud.

According to court documents, Harwood and his co-conspirators used aggressive telemarketing to steer Medicare beneficiaries toward unnecessary orthotic braces and genetic tests. Harwood paid physicians to sign orders for these items, even though the physicians had no genuine relationship with the patients and did not comply with Medicare telemedicine requirements. He then sold the signed orders to durable medical equipment (DME) suppliers, laboratories, and marketers that were part of the scheme. He also billed Medicare through several Florida DME companies that he owned.

The government claims that, in total, the scheme generated $46.2 million in false claims to Medicare, of which Medicare paid $17.9 million, and that Harwood personally received more than $10.4 million from the scheme.

Read the DOJ’s press release here.

The case is United States v. Harwood, No. 0:25-CR-60138, in the US District Court for the Southern District of Florida. 

Texas Couple Sentenced for Billing Medicare Millions for Phantom Wheelchair Repairs

On October 23, the US Attorney’s Office for the Southern District of Texas announced that Jeremiah Yzaguirre and his wife, Maria Luisa Yzaguirre, both of Harlingen, Texas, were sentenced for defrauding Medicare through their DME business, Southwest Medical Homepatient.

The Yzaguirres’ company was enrolled in Medicare as a DME supplier and held itself out as providing power wheelchair parts and repairs. According to the government, from 2019 through 2023, the couple caused Medicare to be billed roughly $14 million for power wheelchairs, parts, and repairs for only 37 beneficiaries. The couple pleaded guilty in April 2025, both admitting to receiving millions of dollars for parts that were never provided and repairs that were never performed. Approximately $736,072 was billed for one beneficiary alone. Investigators found that the couple spent the proceeds on cryptocurrency, a vehicle, electronics, collectibles, and purses.

Jeremiah Yzaguirre was sentenced to 110 months in prison and Maria Luisa Yzaguirre was sentenced to 80 months in prison. They were both also ordered to pay $9,248,976 in restitution to Medicare and a $25,000 fine. 

Read the press release from the US Attorney’s Office for the Southern District of Texas here.

The case is United States v. Yzaguirre, No. 1:23-CR-00516, in the US District Court for the Southern District of Texas.