On April 30, 2026, the Department of Justice’s (“DOJ”) National Fraud Enforcement Division (“Fraud Division”) announced the formation of the West Coast Health Care Fraud Strike Force, a multi-district enforcement initiative spanning Arizona, Nevada, and the Northern District of California. [1] Announced by Assistant Attorney General Colin McDonald, the new Strike Force signals a significant
HHS Inspector General Reminder: Kickback Liability Turns on Intent, Not Market Value or Stark Law Compliance
The U.S. Department of Health and Human Services Office of Inspector General (OIG) updated its FAQs on Fraud and Abuse Authorities to add a new answer on fair market value (FMV) in FAQ 17 and revise the answer on how the physician self-referral law (Stark Law) overlaps with the federal Anti-Kickback Statute (AKS) in FAQ
FAR Council Issues Implementation Guidance for Executive Order 14398: New DEI Contract Clause Requirements for Federal Contractors
On April 20, 2026, the Federal Acquisition Regulatory (FAR) Council issued agency implementation guidance for Executive Order (E.O.) 14398, “Addressing DEI Discrimination by Federal Contractors,” which President Trump signed on March 26, 2026. The guidance introduces a new contract clause — FAR 52.222-90 — and establishes tight deadlines for agencies to incorporate the clause
U.S. Court Blocks Texas Food Labeling Statute; Manufacturers Should Watch Appeal
A federal court blocked the enforcement of a Texas law requiring food manufacturers to place conspicuous warning labels on products containing one or more of the statute’s listed ingredients. The court’s decision in American Beverage Association, et al. v. Paxton, Case No. 6:25-CV-00566-ADA-DTG (W.D. Tex., Dec. 5, 2025) — and the appeal that followed — could
As FTC Increases Enforcement of Made in USA Claims, Companies Should Prepare for More Regulatory Attention
On March 13, 2026, the Trump administration issued an executive order directing the Federal Trade Commission (FTC) to prioritize enforcement actions against unlawful Made in USA statements, signaling heightened scrutiny of country-of-origin representations. In the wake of this directive, on April 14, 2026, the FTC announced enforcement actions and settlements involving three companies alleged to
GSA AI Procurement Rules Would Introduce New Disclosure and Use-Rights Requirements for Federal Contractors
The General Services Administration (GSA) Federal Acquisition Service has released draft contract terms and conditions related to artificial intelligence (AI)-related procurements through a new proposed GSAR clause 552.239-7001, “Basic Safeguarding of Artificial Intelligence Systems (FEB 2026) (GSAR Deviation), that would impose material new requirements on contractors and service providers supplying artificial intelligence capabilities to the
Old Wine, New Bottles? FinCEN Proposes to Codify AML/CFT Program Standards for Financial Institutions
On April 7, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a Notice of Proposed Rulemaking (“NPRM”) that would formalize and, in certain respects, update the requirements for financial institutions’ anti-money laundering and countering the financing of terrorism (“AML/CFT”) programs under the Bank Secrecy Act (“BSA”). While FinCEN has characterized
Long Anticipated Medicare Advantage Compliance Guidance Heightens Investor and Provider Scrutiny
In February 2026, the Department of Health and Human Services, Office of Inspector General (HHS-OIG) issued its highly anticipated Industry Compliance Program Guidance for Medicare Advantage (MA ICPG), the first such compliance guidance for the MA industry in over 25 years. The MA ICPG is the second industry segment-specific compliance guidance published in a series
CMS Reaches $100 Million in Stark Self-Disclosure Settlements
The Centers for Medicare & Medicaid Services (CMS) recently released data on its 2025 settlements of voluntary self-disclosures related to past violations or potential violations of the physician self-referral law (the Stark Law). Generally, two notable items arise from our annual review of CMS’ settlement data. First, CMS has now reported aggregate settlements reaching $105,090,031.
Ninth Circuit Ruling in FCA Case Predicated on 340B Pricing Violations Has Significant Implications for Pharma Manufacturers
On March 17, 2026, the United States Court of Appeals for the Ninth Circuit issued a significant opinion in United States ex rel. Adventist Health System of West v. AbbVie Inc., [1] reversing the district court’s dismissal of a qui tam complaint brought under the False Claims Act (“FCA”) against four major drug manufacturers. The