District of Massachusetts Joins the Main Justice Health Care Fraud Strike Force
Earlier this week, the U.S. Department of Justice's Criminal Division announced the expansion of its Health Care Fraud Unit's New England Strike Force to include the District of Massachusetts. The move was announced as a strategic enhancement to federal enforcement resources in one of the nation's most significant health care and life sciences hubs.
The U.S. Attorney's Office for the District of Massachusetts has a notable track record in health care fraud enforcement. In fiscal year 2025 alone, the office recovered over $450 million in fraudulently obtained funds between its own Health Care Frauds and Affirmative Civil Enforcement Units. This record is the latest accounting in a long history of robust and sophisticated enforcement efforts in Massachusetts.
New initiative = Increased Data-Driven Enforcement
So why this move, and why now?
According to the Strike Force, it employs a data-driven, multi-agency model that leverages sophisticated data analytics and financial-tracing techniques to target complex fraud schemes. This approach is supposed to allow for the identification and prosecution of both individual and corporate actors engaged in fraudulent activities that undermine the integrity of the U.S. health care system. The Strike Force's operations are supported by a coalition of federal and state agencies, including the FBI, HHS-OIG, DHS, FDA, IRS, VA-OIG and others, ensuring a comprehensive enforcement strategy.
These approaches are tried and true in building good health care fraud cases, and the District of Massachusetts has long employed them, both on its own, and in partnership with other Districts and "Main Justice."
What to Expect
According to Main Justice, the reason for expanding the Health Care Fraud Unit's New England Strike Force is to bring enhanced federal enforcement resources to one of the nation's most significant centers of health care and life sciences. We should take them at their word.
Indeed, allocating additional enforcement resources to one of the most effective U.S. Attorney's Offices in the country is sure to result in increased enforcement and broader targeting. Geographic boundaries should create less friction, and the timeline for bringing these cases is likely to shrink.
But added resources could also come with some strings. Although it remains to be seen how this plays out, it is likely that the Fraud Section of Main Justice will be jointly leading the regional efforts. These partnerships are not particularly novel, but when they are formalized in this way, they bring targeting information, investigative priorities, and other "Main Justice" influences to local investigations. Thus, for the line AUSAs and their management in Massachusetts, there is reason to consider whether this integration may be a means not only to enhance the capabilities of enforcement in the District, but also on occasion for Washington, D.C. to direct them.
Greater Whistleblower Activity
Companies operating within the life sciences and health care sectors, and particularly those involved in pharmaceuticals, medical devices, and health care services, should be aware of the increased scrutiny and enforcement actions that may arise from this integration.
The expansion of the Strike Force and the attendant publicity and reach is also likely to result in an increase in qui tam referrals to the U.S. Department of Justice. Qui tam actions, brought under the False Claims Act (FCA), allow whistleblower relators to report fraudulent conduct against government programs. With the enhanced enforcement capabilities of the Strike Force, individuals and entities may be more inclined to report suspected fraud, leading to a potential rise in qui tam cases from throughout the region, if not more broadly. The FCA has been a favored tool of the Department through 2025, and we should expect its use to continue, whether for health care fraud, or any other fraud related to the disbursement of federal monies, or the failure to pay the federal government what is owed.
Conspicuously, the Strike Force maintains a presence in several regions across the country, but not in many other important judicial districts. This integration of the District of Massachusetts therefore may signal a new approach to how the Department wants to prosecute these cases, and we should expect them to want to show clear results quickly.
Vigilance and Compliance Systems
Companies operating in health care and life sciences should be prepared for increased enforcement actions and consider redoubling robust compliance programs to mitigate potential risks, including channels for whistleblower complaints. The Strike Force's presence in Massachusetts underscores the importance of maintaining ethical practices and transparency in all health care-related operations and, when necessary, to responsibly engage with the Department.
