How DOJ Healthcare Fraud Strike Forces Operate
A strike force is a standing team of federal prosecutors and agents assigned to healthcare fraud in a specific region, working from billing data rather than complaints. Our attorneys at Chapman, Dowling & Mallek defend providers targeted by these teams.
Who Actually Sits on a Strike Force?
Strike forces work because they put every agency at one table from day one. A typical team draws from the following:
- Trial attorneys from the Department of Justice (DOJ) Criminal Division Fraud Section
- Assistant United States Attorneys from the local district
- Agents from the Federal Bureau of Investigation (FBI)
- Investigators from the Department of Health and Human Services Office of Inspector General
- State Medicaid Fraud Control Units and, in prescribing cases, the Drug Enforcement Administration (DEA)
Pooling agencies removed the delays that once slowed these cases down. Records, subpoenas, and analysts now move between offices in days instead of months.
How Data Analytics Picks the Targets
Analysts compare your claims against every other provider billing the same codes nationally. Investigators may flag sudden billing growth, atypical coding patterns, or patient counts that appear inconsistent with available staff, even when no one has reported suspected misconduct.
Why Are Strike Forces Placed in Certain Cities?
Deployment follows the data. Detroit received one of the original strike force placements when the program began in March 2007. That means that Michigan providers have been measured against national billing baselines for nearly two decades longer than practices in most other states.
Placement also affects the local docket. Cases run through the Eastern District of Michigan, where prosecutors and agents have handled hundreds of health care matters and where the same defense arguments have been tested repeatedly.
Enforcement Priorities Driving Current Cases
Resources concentrate where reimbursement grew fastest, and oversight lagged. Current priorities center on the following:
- Wound care products and skin substitutes billed without documented medical necessity
- Hospice and home health services for patients who did not qualify
- Telehealth arrangements that generated orders without real patient encounters
- Kickbacks disguised as consulting, marketing, or management fees
Federal cases may target business owners, executives, and treating clinicians in addition to the organization itself. Individual accountability remains a central enforcement priority, a position the Centers for Medicare & Medicaid Services (CMS) reinforced in the latest takedown announcement.
What Does Individual Accountability Mean for You?
Conspiracy is the charge reaching the most people. Under 18 U.S.C. § 1349, agreeing to a fraudulent scheme carries the same penalty as completing one, which is how office managers and billing staff end up as defendants.
Your title matters less than what the government can show you knew. Defenses often turn on proving that someone relied in good faith on published billing guidance or a supervisor’s assurances.
Meet a Strike Force Investigation With a Prepared Defense
Picture a team of prosecutors, agents, and data analysts who studied your billing for two years before you learned your practice had a file. Chapman, Dowling & Mallek brings an intensive, collaborative approach to every federal matter, and our attorneys handle these cases from the first records request through verdict. Call (346) 242-7626 for a free consultation with our federal trial attorneys.