DOJ Revises False Claims Act Manual to Clarify Enforcement Standards
The Department of Justice updated its False Claims Act manual on September 18, 2026, reinstating and expanding a 2017 policy that subregulatory guidance cannot impose legal obligations beyond those established by statute or regulation. The revision aims to promote fairness and effective enforcement in fraud cases. The change affects how DOJ evaluates and pursues False Claims Act cases, including those involving Medicaid providers and health plans. The updated standards took effect immediately upon publication.
The revised enforcement framework may narrow the basis for Medicaid fraud allegations, potentially reducing exposure for providers and managed care organizations whose compliance practices rely on subregulatory guidance rather than explicit statutory or regulatory requirements.
Managed Care
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