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DOJ and HHS Set April 22, 2027 Deadline for Healthcare False Claims Act Self-Disclosure Pilot

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Why it matters

The DOJ Civil Division and HHS announced a six-month self-disclosure pilot on October 22, 2026, that lets healthcare companies resolve potential civil False Claims Act exposure by coming forward voluntarily. Participating companies pay between 1.25 and 1.6 times a DOJ-calculated base amount and receive a federal civil release without factual admissions. They also avoid a Corporate Integrity Agreement. Under the pilot, HHS's Office of Inspector General will not impose exclusion, CMS will not revoke billing privileges, and neither agency will impose civil monetary penalties. The program is a joint effort of DOJ's Civil Division and HHS's Office of the General Counsel, HHS-OIG, and CMS. Disclosures go to FCA-SDPP@usdoj.gov. The window closes at 11:59 p.m. on April 22, 2027, and late or incomplete submissions will not be reviewed.

Eligibility is narrow. The government must not already know about the conduct, so a disclosure cannot overlap with a pending qui tam complaint. The pilot covers civil liability only. Criminal conduct goes to DOJ's National Fraud Enforcement Division under a separate policy. The announcement does not say whether a permanent self-disclosure option will follow the pilot.

The window is short and the requirements are demanding. A disclosing company must investigate the conduct, quantify its financial impact (often through sampling and extrapolation), assemble exhibits that fully reflect the conduct, write a narrative that cross-references them, implement and document remediation, and secure a certification, all before the deadline. Law firm alerts from late October and early November are urging boards to act now. General counsel should start the internal review immediately, since the timeline leaves little room for a slow start. Counsel should also check for any qui tam activity, because a pending complaint would bar eligibility.

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