Summary
The Upshot
- The announcement follows a record-setting year for health care fraud enforcement, including a series of landmark prosecutions, and builds on previously announced health care initiatives, including the Health Care Fraud Data Fusion Center.
- The Strike Force is the latest signal of the DOJ’s deployment of a broad set of tools—many data-driven—to detect and prosecute billing fraud. Health care fraud enforcement remains a top priority for the Trump administration.
- Following the 2025 National Health Care Fraud Takedown—the largest in DOJ history—the DOJ promised that the takedown was not the end, but rather “the beginning of a new era of aggressive prosecution and data-driven prevention.”
- The creation of the West Coast Strike Force signals that long-term care facilities (LTC) and other providers cannot afford to ignore the escalating enforcement environment—consistent with the administration’s broader enforcement posture, including its continued emphasis on voluntary self-disclosure.
The Bottom Line
What is the West Coast Health Care Fraud Strike Force?
DOJ’s Fraud Division announced the West Coast Health Care Fraud Strike Force on April 30, 2026, as a multidistrict enforcement initiative uniting the Division’s Health Care Fraud Section with the U.S. Attorney’s Offices for the District of Arizona, the District of Nevada, and the Northern District of California.
The Strike Force brings together the Fraud Division’s Health Care Fraud Section with three U.S. Attorney’s Offices and key law enforcement partners, including the Health and Human Services Office of the Inspector General (HHS-OIG), the FBI, and the DEA, reflecting an “urgent and undeniable” need for coordinated action in the region and a “whole-of-government” approach to combating health care fraud in the region.
The DOJ is investing heavily in data-driven enforcement, including its Health Care Fraud Data Fusion Center, which will use AI and cloud computing to identify billing anomalies. The expanded enforcement effort responds to data showing what the DOJ described as “a significant and accelerating increase in health care fraud across all three districts,” and the “migration of fraud schemes to Arizona and Nevada.”
As Assistant Attorney General Colin McDonald stated, the Fraud Division is “committed to bringing that same relentless, data-driven prosecutorial force to bear across every corner of this region, making unmistakably clear that no scheme is too sophisticated, no network too large or small, and no fraudster too distant to escape federal accountability.”
The creation of the West Coast Strike Force builds on the recent expansion of the Strike Force program to the District of Massachusetts, along with a record-setting year for health care enforcement in 2025. This included the largest-ever National Health Care Fraud Takedown, which charged more than $15 billion in alleged losses and resulted in over $560 million returned to the public.
The Strike Force also complements the recently announced Health Care Fraud Fusion Center, which may accelerate the detection and prosecution of billing fraud. The Data Fusion Center brings together experts from the DOJ’s Health Care Fraud Unit Data Analytics team, the HHS-OIG, the FBI, and other agencies to leverage artificial intelligence and cloud computing to identify health care fraud schemes. For long-term care facilities, this means that billing data is being collected from disparate sources, allowing prosecutors to quickly spot trends and anomalies.
What Recent Cases Highlight About the DOJ’s Enforcement Priorities
Recent landmark prosecutions demonstrate the DOJ’s willingness to pursue aggressive sentences, substantial asset forfeiture, and parallel civil enforcement under the False Claims Act.
The DOJ’s announcement cited several landmark prosecutions that illustrate the types of cases the Strike Force will target.
In the first prosecution of its kind, two Arizona wound graft company owners were sentenced to 15.5 years and 14 years in prison for causing over $1.2 billion in false and fraudulent claims to be submitted to Medicare and other health insurance programs for medically unnecessary grafts tied to illegal kickbacks. From November 2022 through May 2024, the owners directed medically untrained “sales representatives” to identify elderly Medicare beneficiaries—many in hospice care—and order expensive, bioengineered skin grafts regardless of medical necessity. Nurse practitioners were instructed to “suspend their medical judgment” and apply whatever grafts were ordered, resulting in applications to nonexistent wounds and to terminally ill patients, some of whom died within days or even the same day of application. The government seized $126 million in assets, including cash, luxury vehicles, and gold bars, and the defendants were ordered to pay over $600 million each in restitution. The civil resolution under the False Claims Act was originally brought by whistleblowers under the Act’s qui tam provisions.
The DOJ also cited the conviction of a Silicon Valley medical technology company president, who was sentenced to eight years in prison in the first criminal securities fraud case related to COVID-19. Additionally, the owner of a Pakistan-based medical billing company was indicted for an alleged scheme exploiting substance abuse patients at over 41 Arizona clinics, and fraudulently billing Arizona Medicaid for over $650 million.
Implications for LTCs
Medicare and Medicaid fraud are not new. What is new is the combination of the Strike Force and the DOJ’s data-driven detection capabilities. Together, these initiatives signal a materially more aggressive enforcement environment. In-house counsel at long-term care facilities and other health care providers should take the following practical steps:
- Identify High-Risk Billing Areas: Conduct targeted reviews of billing categories most susceptible to data-driven detection (e.g., high-cost procedures) where statistical outliers are more likely to draw scrutiny. Billings patterns that deviate from expected norms can trigger investigation.
- Know Your Data Before the Government Does: Ensure that the company has the ability to identify billing trends, volume spikes, and coding anomalies across facilities. Internal detection and investigation of anomalies—before they are flagged externally—creates an opportunity to remediate and, where appropriate, to consider self-disclosure.
- Strengthen Internal Reporting Mechanisms: The DOJ’s Corporate Whistleblower Awards Pilot Program creates a direct financial incentive for employees to report misconduct. Internal compliance channels should be accessible, credible, and well-publicized. Investigate complaints promptly, protect against retaliation, and escalate substantiated findings to senior leadership and outside counsel.
Ballard Spahr’s White Collar Defense and Investigations Group advises health care clients in navigating changing DOJ priorities, as well as responding to governmental requests and investigations and civil enforcement proceedings.
We are currently advising clients on a host of these topics. Please contact us if we can assist you in advice and counsel regarding such matters or in responding to active inquiries, investigations, or proceedings.
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