- within Coronavirus (COVID-19) topic(s)
On April 30, 2026, the Department of Justice’s (DOJ) National Fraud Enforcement Division (the Division) announced the launch of a new West Coast Strike Force, a multi-district enforcement initiative joining the Division’s Health Care Fraud Section with U.S. Attorney’s Offices for the Districts of Arizona, Nevada, and Northern California. This new initiative builds on other DOJ Strike Force efforts across the country and signals a significant expansion of the federal government’s efforts to combat health care fraud in the western United States. It reflects the government’s continued prioritization of health care fraud enforcement and its commitment of additional resources to identify, investigate, and prosecute fraudulent schemes targeting federal health care programs, including Medicare, Medicaid, Tricare, and others.
This new effort is consistent with the Trump administration’s formation of a separate DOJ Fraud Division and is another high-profile enforcement “splash.” The West Coast Strike Force will channel federal enforcement attention and resources to the region. It is important that health care industry stakeholders be aware of the Strike Force and mitigate compliance risks now.
Background: The Health Care Fraud Strike Force Model and Broader Enforcement Landscape
DOJ’s Health Care Fraud Strike Force (the Strike Force) program has long served as a cornerstone of the federal government’s anti-fraud enforcement strategy. The Strike Force model pairs federal prosecutors from the DOJ with the Federal Bureau of Investigation (FBI), Department of Health and Human Services Office of Inspector General (HHS-OIG), the Drug Enforcement Administration (DEA), and other federal law enforcement agents to concentrate investigative and prosecutorial resources in geographic regions identified as having high levels of health care fraud activity. Recent years have seen the government pursue increasingly aggressive strategies, including greater reliance on data analytics to identify patterns of outlier billing, expanded use of the False Claims Act (FCA) and its qui tam provisions, and enhanced coordination between federal and state enforcement authorities. FCA lawsuits driven by whistleblowers continue to be a significant driver of health care fraud investigations, and the government has demonstrated a sustained willingness to pursue both individual and corporate liability.
The launch of the West Coast Strike Force is part of a broader trend of heightened federal enforcement activity targeting fraud and abuse in the health care sector. The West Coast Strike Force joins the following existing geographical Strike Forces: the New England Strike Force, covering New Hampshire, Maine, Massachusetts, and Vermont, the Northeast Strike Force, covering New York and New Jersey, the Florida Strike Force, the Midwest Strike Force, covering the central United States region, the Gulf Coast Strike Force, covering New Orleans, Baton Rouge, and Gulfport, the Texas Strike Force, and the Los Angeles Strike Force. Further, 2025 was a record-setting year for health care enforcement.
Per the DOJ, the West Coast Strike Force builds on a foundation of recent high-profile prosecutions in Northern California and Arizona, including a prosecution of digital health technology executives and the dismantling of Medicaid, sober home, and wound care fraud schemes, and data analytics revealing that fraud schemes have migrated to Arizona and Nevada.
Key Takeaways
Concentrated Geographic Focus. The creation of a West Coast Strike Force indicates that DOJ will more aggressively pursue health care fraud schemes in Arizona, California, Nevada and other western United States. Health care providers, suppliers, and other stakeholders operating in the western United States should be aware that federal enforcement scrutiny in their region will almost certainly intensify.
Interagency Coordination. Consistent with the broader Strike Force model, the West Coast Strike Force is expected to leverage the combined resources and expertise of multiple federal agencies, including the FBI, HHS-OIG, DEA and potentially other federal and state partners. This interagency approach allows for more sophisticated and wide-ranging investigations, drawing on data analytics, billing pattern analysis, and traditional investigative techniques. Sophisticated mining of the extensive data submitted to bill Federal Health Care Programs is an established and increasing enforcement approach, and a strong defense requires experience with analyzing and combatting these techniques.
Targeted Fraud Schemes. While the Strike Force program addresses a broad range of health care fraud, historically targeted schemes have included fraudulent billing for services not rendered, upcoding, unbundling, illegal kickback arrangements, medically unnecessary treatments, and schemes involving telemedicine, durable medical equipment, clinical laboratories, and compounding pharmacies. See DOJ Fraud Section Year in Review 2025. These areas cut across medical specialties and practice settings, and require providers to have effective compliance protocols concerning all areas of contracting, service, and billing.
Practical Guidance for Health Care Industry Stakeholders
Health care providers and industry participants operating in the western United States should take the Strike Force launch seriously and should consider taking the following steps to reduce enforcement risk.
Review Your Internal Compliance Structure
Health care providers and industry participants should proactively assess their existing compliance programs and practices, and enhance any ineffective areas. Organizations that invest in robust compliance infrastructure and respond promptly and appropriately to potential issues will be best positioned to navigate this intensified enforcement environment.
Review Your Billing Practices
Improper billing remains a primary target of Strike Force investigations. Providers should comprehensively review their billing practices to ensure that claims submitted to Federal Health Care Programs accurately reflect the services rendered, are supported by adequate documentation, and comply with applicable coding and billing rules.
Assess Your Relationships with Referral Sources and Other Third-Parties
Organizations should review their relationships with referral sources, vendors, and other third parties to ensure compliance with the federal Anti-Kickback Statute and the Stark Law. Arrangements involving remuneration in exchange for referrals of Federal Health Care Program business — all of which the government views broadly — remain a core focus of government enforcement efforts. Many practices that organizations believe are routine and innocent “business as usual” may be viewed by prosecutors as impermissible kickback.
Proactively Address Self-Identified Compliance Issues
Providers who identify potential compliance issues should consider whether to voluntarily self-disclose under established protocols — e.g., HHS-OIG Self Disclosure Protocol. The government has generally indicated that entities that come forward voluntarily may receive more favorable treatment than those whose misconduct is discovered through investigation or whistleblower complaints.
Engage Legal Counsel
It is critical that entities or individuals who receive a subpoena, civil investigative demand, or other indication of government investigation promptly engage experienced legal counsel to protect its rights and develop appropriate response strategies.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
[View Source]
