On June 30, 2025, the Department of Justice announced the results of its 2025 National Health Care Fraud Takedown (“2025 Takedown”). The 2025 Takedown resulted in: (1) criminal charges against 324 defendants, including 96 medical professionals, for fraud schemes involving over $14.6 billion in intended loss; (2) civil charges for False Claims Act (“FCA”) violations against 20 defendants for $14.2 million in alleged fraud losses and settled FCA cases against another 106 defendants for a total recovery of another $34.3 million; (3) the Centers for Medicare & Medicaid Services preventing the payment of over $4 billion in fraudulent Medicare and Medicaid payments; and (4) asset seizures valued at over $245 million, including extensive cryptocurrency holdings.
Operation Gold Rush
Operation Gold Rush, a part of the nation-wide takedown, exposed a transnational criminal organization (“TCO”) that orchestrated a multi-billion-dollar scheme targeting Medicare.
The TCO submitted over $10.6 billion in fraudulent claims for urinary catheters and other durable medical equipment (“DME”) by exploiting the stolen identities and confidential medical information of more than one million Americans, impacting individuals in all 50 states. To further its scheme, the TCO engaged in a sophisticated money laundering and used shell companies and cryptocurrency to obscure the illicit origins of its ill-gotten funds. The government prevented the TCO from receiving all but approximately $41 million of the approximately $4.45 billion that it was scheduled to receive from Medicare.
In addition, to date, the government seized $27.7 million in fraud proceeds as part of the operation. Unfortunately, the scheme nonetheless resulted in payments of approximately $900 million from Medicare supplemental insurers which have yet to be recovered. Nineteen individuals have been charged in five district courts across the country for their respective roles in the scheme.
New DOJ Health Care Fraud Initiatives
The 2025 Takedown coincided with the announcement of two DOJ initiatives intended to increase the effectiveness of its health care fraud prosecutions.
- Health Care Fraud Data Fusion Center. DOJ announced the creation of the Health Care Fraud Data Fusion Center, which will leverage advanced analytics, artificial intelligence, and inter-agency collaboration into enhanced fraud detection and prosecution capabilities. The Center seeks to break down information silos unintentionally created by government agencies, improve operational efficiency, and quickly identify emerging fraud trends.
- DOJ-HHS False Claims Act Working Group. The team will help facilitate collaboration between the departments to advance “priority enforcement areas,” including investigating possible FCA violations involving: (1) Medicare Advantage, (2) pharmaceutical, DME, and laboratory testing pricing, (3) barriers to patient access to care, (4) violations of the Anti-Kickback Statute for pharmaceuticals, medical devices, and DME, (5) defective medical devices, and (6) the manipulation of electronic health records.
Key Takeaways
- Alignment with DOJ White Collar Priorities. Earlier this year, DOJ released a memo outlining its white collar priorities under the current administration. Chief among them were waste, fraud and abuse; fraud that threatened people’s health and safety; crimes against the U.S. financial system, particularly those committed by TCOs; complex money laundering schemes; violations of the controlled substances act; and the use of digital assets in furtherance of other criminal conduct. Virtually all the indictments resulting from the 2025 Takedown involve two or more of these priorities, notably being crimes committed by TCOs, associated money laundering schemes, and the seizure of cryptocurrency valued in the millions of dollars.
- Traditional Areas of Focus Still in Play. The 2025 Takedown still reflects well-known areas of government enforcement in the health care space, including violations of the Anti-Kickback Statute, violations of the Control Substances Act, as well as indictments related to medical enterprises and combine telehealth, aggressive marketing tactics, and the prescribing of DME or laboratory testing without medical necessity.
- Whole-of-Government Approach to Health Care Enforcement. The use of sophisticated fraud techniques, including international money laundering and cyber tactics such as forging digital consent, reflects the evolving nature of health care fraud. Current trends suggest perpetrators leverage technology to obscure their activities. To combat this evolution in complexity, the government is applying a whole-of-government approach, allowing it to combine and maximize its resources by combining resources toward a common goal, as exemplified by the creation of the Health Care Fraud Data Fusion Center and the DOJ-HHS False Claims Act Working Group.
- Increase in Cybersecurity Threats. The 2025 Takedown highlights the increasing threat that cybersecurity vulnerabilities have created in the health care industry. Several charged defendants were alleged to have hacked into health care computer systems to steal personal health information, which was then used to submit fraudulent claims. Some schemes even employed artificial intelligence to fabricate patient consent recordings, further complicating detection efforts. These actions underscore the need for health care companies to ensure their cybersecurity measures are robust. Protecting sensitive patient health data from unauthorized access and manipulation should remain a top priority.
- Potential Inquiries into Banks. The pervasive presence of money laundering and bank fraud charges in the 2025 Takedown highlights the sophistication of modern health care fraud defendants. It also highlights that DOJ is not just focused on health care fraud, but the additional conduct by violators in the furtherance of their crimes, including exploiting America’s financial institutions. Health Care fraud is increasingly committed by sophisticated criminals who have the resources and knowledge to move large sums of money across borders and through complex financial networks, thus amplifying the scale of the fraud. To do this, health care fraud perpetrators need to either enlist or deceive financial institutions in furtherance of their schemes. We expect financial institutions to see an uptick in enforcement activity. These may range from collecting information to investigating Bank Secrecy Act violations for failure to report suspicious activity, along with investigations into potential conspiracy, wire fraud, and money laundering.
- Importance of Compliance. Companies in the health care industry should continue to follow and monitor as we are likely to see continued ramp up by the DOJ in the health care enforcement space. Further, the DOJ announced earlier this year the expansion of its corporate whistleblower program to now also cover tips pertaining to health care fraud involving public health care programs (and not just private insurers not otherwise subject to the FCA, as contemplated by the prior iteration of the DOJ’s whistleblower program). As a result, companies would be well advised to proactively review and strengthen their compliance programs to ensure the appropriate internal controls are in place to effectively help mitigate enforcement risk.
[View source.]
