On April 30, 2026, the Department of Justice (“DOJ”) announced the creation of the West Coast Health Care Fraud Strike Force, a coordinated enforcement initiative focused on healthcare fraud in Arizona, Nevada, and Northern California. The initiative brings together DOJ’s Health Care Fraud Unit and the relevant U.S. Attorney’s Offices for those states, in coordination with the Office of Inspector General for the United States Department of Health and Human Services (“HHS-OIG”), the Federal Bureau of Investigation (“FBI”), the Drug Enforcement Administration (“DEA”), and other law enforcement.

The announcement follows DOJ’s recent creation of the National Fraud Enforcement Division and reflects the federal government’s continued emphasis on coordinated healthcare fraud enforcement across federal agencies. The West Coast expansion also follows DOJ’s September 2025 expansion of the New England Strike Force into Massachusetts, where the government emphasized the region’s role as a major healthcare and life sciences investigative and enforcement hub.

DOJ first launched the Health Care Fraud Strike Force model in 2007 as part of a broader effort to combat Medicare fraud and related healthcare offenses. For nearly two decades, DOJ and HHS-OIG have coordinated teams of prosecutors, investigators, and data analysts to identify suspicious billing patterns, emerging fraud schemes, and healthcare fraud “hot spots” nationwide. DOJ reports that Strike Force investigations have resulted in the prosecution of over 6,200 defendants involving over $45 billion in allegedly fraudulent billings.

Since the inception of the Strike Force, DOJ has increasingly relied on advanced data analytics and interagency information-sharing initiatives to identify potential fraud trends. DOJ has emphasized the use of coordinated analytics efforts, including the Healthcare Fraud Data Fusion Center, which facilitates information sharing among DOJ, HHS-OIG, FBI, and DEA investigators and analysts. These efforts may allow regulators to identify anomalous billing patterns and emerging fraud schemes more quickly.

DOJ’s announcement also reflects the government’s growing focus on technology-enabled healthcare fraud risks. In recent years, enforcement agencies have scrutinized telehealth arrangements, digital health platforms, diagnostic testing companies, and other business models that combine technology, patient acquisition, and federal healthcare program billing to ensure consistency with federal regulatory expectations. In its announcement, DOJ specifically highlights recent prosecutions involving digital health executives and healthcare technology-related fraud schemes in Northern California and Arizona.

Northern California’s inclusion in the Strike Force initiative is particularly notable given the region’s concentration of digital health, artificial intelligence (“AI”), and healthcare technology companies. As AI-enabled tools continue to proliferate and become increasingly integrated into healthcare billing, coding, documentation, patient intake, and operational workflows, regulators may increasingly examine whether the technologies and their use create compliance risks involving unsupported claims, inaccurate documentation, improper reimbursement practices, or insufficient oversight.

At the same time, Arizona and Nevada have faced increased enforcement attention involving alleged hospice fraud schemes. Recent reports, including by the Medicare Payment Advisory Commission (aka, MedPAC), have identified unusually rapid hospice provider growth in Arizona and Nevada, as well as California.[1] Those reports also found other indicators that federal regulators often associate with elevated hospice fraud risk, including abnormal utilization patterns and provider concentration concerns.

Healthcare providers, digital health companies, pharmaceutical manufacturers, life sciences companies, and healthcare technology vendors operating in these regions should expect increased scrutiny involving billing and reimbursement practices, telehealth arrangements, and AI-enabled operational tools. To mitigate this potential risk, companies should consider reviewing compliance controls, internal auditing procedures, vendor oversight practices, and governance structures relating to automated systems that affect coding, billing, documentation, or reimbursement determinations.

The creation of the West Coast Health Care Fraud Strike Force signals DOJ’s continued expansion of data-driven healthcare enforcement into technology-focused markets and suggests increasing federal scrutiny of AI-enabled and technology-driven healthcare business models. Proskauer’s Health Care Group will remain up-to-date on this and other DOJ enforcement efforts.


[1] We note that CMS recently announced a six-month, nationwide moratorium on new Medicare enrollments for hospices and home health agencies, effective May 13, 2026. The moratorium applies to initial Medicare enrollment applications and certain changes in majority ownership, although existing enrolled providers may continue operating and billing Medicare. CMS stated that the moratorium is intended to combat fraud, waste, and abuse in “high-risk” provider categories and will be accompanied by expanded data analytics, targeted investigations, and heightened scrutiny of providers suspected of fraudulent activity. CMS’s efforts for these purposes appear to align with DOJ’s creation of the West Coast Health Care Fraud Strike Force, among its other investigative and enforcement models.

Lara Feder

Lara Feder is a law clerk in the Corporate Department and is a member of the Health Care Group.

Photo of Matthew J. Westbrook Matthew J. Westbrook

Matt Westbrook is a senior counsel in the Corporate Department and a member of the Health Care Group. His practice focuses on providing regulatory compliance advice for the Firm’s health care clients, including service providers, health plans, operators, investors, and lenders, among others.

Matt Westbrook is a senior counsel in the Corporate Department and a member of the Health Care Group. His practice focuses on providing regulatory compliance advice for the Firm’s health care clients, including service providers, health plans, operators, investors, and lenders, among others. Matt specifically provides advice on fraud and abuse matters arising under the Federal False Claims Act (FCA), Civil Monetary Penalties Law, Federal Anti-Kickback Statute (AKS), and Physician Self-Referral Law (Stark Law), as well as on the regulations promulgated by the Drug Enforcement Administration (DEA) and the Department of Health and Human Services, including the Office of Inspector General (OIG), Centers for Medicare & Medicaid Services (CMS), and Food and Drug Administration (FDA).

Before joining the Firm, Matt served as senior counsel in OIG’s Administrative and Civil Remedies Branch. At OIG, Matt was responsible for determining whether to impose administrative sanctions, including civil money penalties and Federal health care program exclusions, against health care providers and suppliers, and whether to impose civil money penalties on hospitals and physicians in connection with matters referred to CMS under the Emergency Medical Treatment and Labor Act (EMTALA). During his tenure, Matt also litigated exclusion appeals before administrative law judges and appellate panels of the Departmental Appeals Board; advised United States Attorney’s Offices on exclusions appealed to Federal district courts; resolved voluntary self-disclosures submitted by providers and grant and contract recipients; and participated in the negotiations and settlements of FCA matters by the Department of Justice involving the AKS, Stark Law, CMS reimbursement issues, and DEA and FDA compliance issues. In connection with certain FCA resolutions, Matt also negotiated and monitored corporate integrity agreements.

On the Florida junior circuit and in college, Matt was a competitive tennis player. Matt played on the varsity team and was captain his senior year at Rhodes College, earning ITA Division III and SCAC All-Academic Honor Roll awards his sophomore, junior, and senior years. Matt is an active member of the American Health Law Association (AHLA) and currently serves as a Vice Chair of AHLA’s Fraud and Abuse Practice Group.

Articles:

Matthew J. Westbrook and David M. Blank, “Using OIG’s Cross-Component Audit and Enforcement Data to Strengthen Your Compliance Program,” Compliance Today (February 2024).

Ed Kornreich, Matthew Westbrook, and Angela Gichinga, “Bracing for the Impact of the No Surprises Act,” Westlaw Today (June 16, 2022).

Presentations:

Bill Mathias and Matt Westbrook, “‘Lightning Round’:  A Fraud & Abuse Due Diligence Game Show,” American Health Law Association (Health Care Transactions Conference, May 5–6, 2025).

Matthew J. Westbrook and David M. Blank, “Recent Trends in CMPL Enforcement, American Health Law Association (Webinar, May 24, 2023).

Photo of Devin Cohen Devin Cohen

Devin Cohen is a partner in the Corporate Department and a member of Proskauer’s Health Care Group.

Devin counsels leading health care organizations and private equity sponsors operating at the cutting edge of the industry on their most important transactional and regulatory matters.

Devin Cohen is a partner in the Corporate Department and a member of Proskauer’s Health Care Group.

Devin counsels leading health care organizations and private equity sponsors operating at the cutting edge of the industry on their most important transactional and regulatory matters. He has a deep understanding of both deal mechanics and the evolving regulatory landscapes in the areas of strategic investment, vertical integration, insurance and brokerage, as well as research.

Over the course of his career, Devin has advised a wide range of health care organizations and investors on value-based care arrangements and initiatives, and routinely advises insurers and providers to structure collaborative care models and Medicare Advantage. In addition, Devin has worked with clients on matters related to pharmaceutical and medical device research and development and clinical trials, including fraud and abuse considerations, human subject protections requirements, animal welfare standards, sponsored and investigator-initiated research negotiations, and compliance monitoring.

Clients value Devin’s responsiveness, as well as his ability to cut through complexity to provide clear, actionable guidance. They also appreciate the strong people skills he brings to the table, which are particularly helpful in negotiations.

Devin’s passion for health care extends to his community service and pro bono efforts in the Boston area. He works with Heading Home and other non-profits providing shelter to those in need throughout the Commonwealth of Massachusetts, among others.

Devin joins Proskauer from Ropes & Gray LLP where he was a partner in the firm’s Health Care practice.

Experience

Devin regularly works with a wide range of health care organizations — including physician groups, academic medical centers, clinical networks, hospitals, dental and management services organizations, insurers, brokers/agents, pharmaceutical and medical device manufacturers, and provider organizations — as well as industry investors, across areas such as:

Health care transactions and investments

  • Provide transactional and regulatory counsel to providers and investors. Examples include:
  • Assisted multiple regional health plans in their mergers and acquisitions of new plans to expand insurance product offerings.
  • Advised a private equity firm on its investment in an online insurance brokerage platform.
  • Counsel investors on emerging state health care transaction laws, corporate practice of medicine, and MSO/DSO structuring.
  • Advise multiple private sponsors on CRO and SMO investments

Value-based care arrangements

  • Counsel a wide range of providers, payors, practice management organizations, vendors and industry investors in the areas of Medicare Advantage, CMMI program participation, state risk-bearing implications and insurance requirements.
  • Advise on strategic partnerships and joint ventures, including innovative collaborations aimed at expanding access to value-based primary care for Medicare beneficiaries.

Regulatory and compliance

  • Routinely counsel Medicare Advantage Organizations, FDRs and program vendors on Medicare Advantage regulatory and contracting standards.
  • Advise investors and brokers/agencies on emerging Medicare requirements, including emerging standards related to sales commissions payments.
  • Advise medical device and pharmaceutical manufacturers on regulatory standards related to customer and patient interactions, marketing and clinician education standards, industry and jointly sponsored CME, patient assistance programs, and related compliance program requirements.

Clinical research and related activities

  • Regularly provide guidance on drug and drug component development/commercialization considerations for sites, investigators and sponsors.
  • Routinely advise institutional and start-up manufacturers, as well as CROs and trial sites, on cutting-edge clinical trial contracting negotiations.
  • Provide counsel on research affiliation agreements, including advising a large academic medical center on developing and implementing its research affiliation agreement with a local pediatric health network.
  • Conduct regulatory diligence for private equity clients regarding their planned investments in companies that participate in the clinical research enterprise.
  • Advise academic medical centers on research misconduct matters.