Every business faces risk — but not all risks come from competitors, market shifts, or economic downturns. Some come from within: legal and compliance risks that can quietly grow until they trigger lawsuits, fines, or regulatory investigations.

For healthcare providers, suppliers, and businesses, few penalties are as devastating as exclusion from Federal healthcare programs. When the HHS Office of Inspector General (HHS-OIG) excludes an individual or entity, they are barred from participating in Medicare, Medicaid, and other federal health programs. This not only cuts off a vital revenue stream but can also damage reputation and cripple operations.

In 2025, the Department of Justice (DOJ) and the Department of Health and Human Services (HHS) announced the creation of a new False Claims Act (FCA) Working Group (https://www.justice.gov/opa/pr/doj-hhs-false-claims-act-working-group). This collaborative initiative brings together prosecutors, regulators, and investigators from across the federal government to aggressively pursue fraud, waste, and abuse in federal healthcare programs.

On May 12, 2025, the U.S. Department of Justice's (DOJ) Head of the Criminal Division, Matthew R. Galeotti, i ssued a memorandum titled...