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Legal·September 21, 2026
DOJ Revises Justice Manual to Strengthen False Claims Act Enforcement
On September 18, 2026, the Department of Justice announced revisions to the Justice Manual strengthening False Claims Act enforcement. The changes affect how DOJ pursues FCA cases, including potential modifications to dismissal policies and limitations on relying on sub-regulatory guidance as the basis for FCA liability. Healthcare providers, including those serving Medicaid beneficiaries, face increased enforcement scrutiny. The revisions took effect immediately upon announcement.
Why it matters
Medicaid providers and managed care organizations face heightened FCA enforcement risk, requiring updated compliance protocols and closer attention to federal billing requirements beyond formal regulations.
Managed Care
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