DOJ Launches West Coast Strike Force to Target Healthcare Fraud Across Arizona, Nevada, and Northern California

05 May 2026
Client Alert

On April 30, 2026, the U.S. Department of Justice’s National Fraud Enforcement Division, in coordination with the U.S. Attorneys for the Northern District of California, Nevada, and Arizona, announced the launch of a new West Coast Health Care Fraud Strike Force. The announcement signals a significant expansion of federal enforcement resources and comes three weeks after the creation of the DOJ’s new National Fraud Enforcement Division. These developments build on an already historic year of healthcare fraud enforcement in 2025.

This new Strike Force will operate out of San Francisco, Las Vegas, and Phoenix, and will focus on fraud against Medicare and Medicaid programs and in the hospice, sober home, and wound care industries. Using the regional Strike Force model (the first of which was launched in Florida in 2007), federal agents from the Federal Bureau of Investigation, Department of Health and Human Services, and Drug Enforcement Administration will coordinate with other federal, state, and local agencies, using both traditional investigative methods and data analytics to identify potentially fraudulent billing practices and geographic fraud “hot spots.”

Latest Step in Ramp-Up of Healthcare Fraud Enforcement

The West Coast Health Care Fraud Strike Force is the latest in a series of federal and state initiatives demonstrating an unmistakable increase in health care fraud enforcement. During the DOJ’s 2025 National Health Care Fraud Takedown, the department filed criminal charges against 324 defendants across 50 federal districts in coordination with 12 state attorneys general. The cases involved approximately $14.6 billion in intended loss and spanned a wide range of schemes, including hospice, telehealth, and durable medical equipment fraud. That figure reflects just a single coordinated enforcement action in mid-2025, not the total universe of 2025 cases.

Federal and state enforcement has only increased in scope and speed in 2026, with California a major focus.  In April 2026 alone:

  • The California Attorney General charged 21 defendants in a $267 million Medi-Cal hospice fraud scheme involving the alleged use of stolen identities and shell hospice companies billing for services that were never provided.
  • Federal prosecutors in the Central District of California (which has its own regional healthcare strike force) charged eight defendants—ranging from healthcare professionals to operators—for participating in an alleged $50 million scheme involving hospice companies that billed Medicare for patients who were not terminally ill.

We identify four prevailing themes in healthcare fraud enforcement:

1. Data analytics will drive investigations

The federal government has signaled a greater reliance on data analytics tools to detect outlier billing, clusters of hospice providers, unusual utilization patterns, and rapid growth. Such data patterns can trigger investigations and charges even without a whistleblower.

2. Government program fraud is the top enforcement target

Companies that receive government funding, whether through Medicaid, Medicare, the Affordable Care Act, or other federal grant programs, should expect increased scrutiny, especially those involved in telehealth, remote prescribing, behavioral health, and substance abuse treatment.

3. Hospice care providers should assume their billing and operations will be audited or investigated

No healthcare sector has received more scrutiny recently from federal and state investigators than hospice care. Providers should expect that trend to continue, with particular attention to the following factors:

  • Patient eligibility and certification (terminal illness determinations);
  • Length-of-stay anomalies and high live-discharge rates; and
  • Relationships between providers and marketers, recruiters, and referral sources.
4. Parallel proceedings are the norm

Providers and other companies in this space should be prepared for parallel state/federal and civil/criminal investigations, and must coordinate legal strategy across all fronts, including:

  • Criminal charges (healthcare fraud, conspiracy, identity theft);
  • Civil False Claims Act exposure; and
  • Payment suspensions, license revocations, and exclusion actions.

Practical Guidance for Healthcare Industry Players

The creation of the West Coast Health Care Fraud Strike Force shows that healthcare technology companies, providers, and investors will continue to be targets for federal and state regulation. This is of particular importance given the concentration of healthcare technology companies in the Northern District of California (which includes Silicon Valley and San Francisco). These companies, and their investors and executives, should be thinking proactively about how to prepare for increased scrutiny, including these proactive compliance and remediation efforts:

  • Follow the HHS-OIG “seven elements” framework (policies, compliance officer, training, auditing, reporting, enforcement, corrective action);
  • Conduct focused audits of government program eligibility determinations;
  • Get billing and coding right by investing in qualified personnel and ongoing training, regular internal audits of claims, and clear documentation;
  • Immediately remediate identified deficiencies; and
  • Review referral relationships for Anti-Kickback Statute risk.

We are Morrison Foerster — a global firm of exceptional credentials. Our clients include some of the largest financial institutions, investment banks, and Fortune 100, technology, and life sciences companies. Our lawyers are committed to achieving innovative and business-minded results for our clients, while preserving the differences that make us stronger.

Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Prior results do not guarantee a similar outcome.