DOJ, HHS-OIG Launch Unified Health Care Fraud Self-Disclosure Policy
On October 15, 2026, DOJ's Fraud Division and HHS-OIG announced a joint policy letting health care entities obtain benefits under both DOJ's Corporate Enforcement Policy and HHS-OIG's Self-Disclosure Protocol through a single disclosure submitted to DOJ's Health Care Fraud Section. DOJ will forward the disclosure to HHS-OIG, eliminating the need for a separate SDP filing, but the benefit is not reciprocal: disclosing only to HHS-OIG generally will not preserve CEP declination eligibility if conduct is later deemed criminal. HHS-OIG also updated its SDP to direct that potentially criminal health care matters be reported to DOJ first. The policy applies to qualifying disclosures made on or after October 15, 2026, and does not resolve mandatory exclusion obligations under the SDP.