On April 30, 2026, the Department of Justice (“DOJ”) announced the creation of the West Coast Health Care Fraud Strike Force, a coordinated enforcement initiative focused on healthcare fraud in Arizona, Nevada, and Northern…
more
/ Criminal Law, Health, Science, Computers, & Technology
2026 has opened with unmistakable signals that False Claims Act (“FCA”) enforcement in the health care sector is accelerating. On January 16, 2026, the Department of Justice (“DOJ”) announced a record-breaking $6.8 billion in…
more
/ Administrative Law, Government Contracting, Health
A newly-introduced Senate bill called the “Break Up Big Medicine Act” proposes a federal prohibition on both new and existing common ownership or control of insurers, pharmacy benefit managers (“PBMs”), drug or medical device…
more
/ Antitrust & Trade Regulation, Health, Insurance
On January 21, 2026, the Office of Inspector General (“OIG”) for the U.S. Department of Health and Human Services (“HHS”) submitted its Fall 2025 Semiannual Report to Congress, identifying investigative outcomes relating to HHS…
more
/ Administrative Law, Health, Insurance
The Office of Inspector General (“OIG”) recently issued advisory opinion 25‑12 (“the Opinion”), which addresses a home care agency’s plan to advertise and pay sign‑on bonuses to prospective attendant‑employees, many of whom are…
more
/ Administrative Law, Health, Labor & Employment Law
In another development in the ongoing litigation over the enforceability of Independent Dispute Resolution (“IDR”) awards issued under the No Surprises Act (“NSA”), two air ambulance providers, Guardian Flight LLC and Med‑Trans…
more
/ Alternative Dispute Resolution (ADR), Health, Insurance
On September 8, 2025, a shareholder of Nutex Health, Inc. (“Nutex”) filed a derivative action in the Southern District of Texas that places the No Surprises Act (“NSA”) squarely at the center of a corporate-governance fight…
more
/ Business Organizations, Health, Securities Law
In a pair of recent back-to-back rulings, Federal district courts in Florida and New York have held that the No Surprises Act (“NSA”) does not permit providers to bring private causes of action to enforce Independent Dispute…
more
/ Administrative Law, Alternative Dispute Resolution (ADR), Health
On May 27, 2025, Blue Cross Blue Shield Healthcare Plan of Georgia (“BCBSGA”) sued several emergency physician groups and their billing agent, Halo MD, alleging abuse of the No Surprises Act’s (“NSA”) independent dispute…
more
/ Alternative Dispute Resolution (ADR), Health, Insurance
Last month, the United States Department of Justice (“DOJ”) issued its “Civil Division Enforcement Priorities” memorandum, memorializing a shift from its predecessor administration’s policy on gender‑affirming healthcare (“DOJ…
more
/ Administrative Law, Criminal Law, Health
In a recently issued opinion, the Fifth Circuit has added yet another chapter to the growing debate over whether providers may seek judicial enforcement of Independent Dispute Resolution (“IDR”) awards issued under the No…
more
/ Alternative Dispute Resolution (ADR), Health, Insurance
The U.S. District Court for the District of Connecticut has become the latest court to weigh in on whether Independent Dispute Resolution (“IDR”) awards issued under the No Surprises Act (“NSA”) are enforceable. In a recent…
more
/ Alternative Dispute Resolution (ADR), Health, Insurance
Over the past 3 years, as chronicled in several Proskauer alerts, an increasing number of states have sought to regulate physician practice management (“PPM”) and private equity transactions in the health care sector, including…
more
/ Business Organizations, Commercial Law & Contracts, Health
The Department of Justice’s (“DOJ”) May 19, 2025 “Civil Rights Fraud Initiative” memorandum, issued by Deputy Attorney General Todd Blanche (the “Initiative”), marks a consequential policy shift for False Claims Act (“FCA”)…
more
/ Civil Rights, Government Contracting, Health
On May 21, 2025, the Centers for Medicare and Medicaid Services (“CMS”) announced a significant expansion of its auditing efforts with respect to Medicare Advantage (“MA”) plans…
more
/ Administrative Law, Health
