The DOJ’s Health Care Fraud Strike Force comes to Massachusetts: What this could mean for companies

What is the Strike Force?

DOJ’s Health Care Fraud Unit began deploying “strike forces” in strategic regions across the U.S. in 2007. “The Strike Force Model consists of interagency teams made up of investigators and prosecutors” that use “advanced data analysis techniques” alongside traditional investigative methods to detect and target health care fraud schemes.

The New England Strike Force previously included the Districts of Maine, New Hampshire, and Vermont. The expansion of the Strike Force to Massachusetts will bring together a long list of federal law enforcement entities – the Federal Bureau of Investigation (FBI), the Department of Health and Human Services Office of Inspector General (HHS-OIG), the Food and Drug Administration (FDA), the Drug Enforcement Agency (DEA), Homeland Security Investigations (HSI), the Department of Veterans Affairs Office of Inspector General (VA-OIG), and the Internal Revenue Service (IRS) Criminal Investigations – to partner with the D. Mass. U.S. Attorney’s Office’s (the Office) existing Health Care Fraud Unit.

The DOJ’s September 23, 2025, announcement also touted a partnership with state agencies: the Strike Force will partner with the Medicaid Fraud Control Unit of Massachusetts and the Insurance Fraud Bureau of Massachusetts.

The announcement describes the partnership as a “force multiplier,” pairing the advanced data analytics capabilities of the Strike Force with the health care fraud legal competencies of the Office.

What this could mean for companies

Massachusetts – particularly Boston, Cambridge and the 128 Belt – is a hub for health care research and innovation. The Office already has a robust Health Care Fraud Unit devoted to policing the industry that, according to the Strike Force announcement, recovered over US$450 million in FY2025 in health care enforcement actions. But the expansion of the Strike Force could mean changes for health care enforcement in Massachusetts. The expansion could lead to:

• More investigations: The Strike Force’s “sophisticated data analytics and financial-tracing techniques” may lead to the detection of more – and broader – fraudulent schemes. With more involvement from the DOJ, we can expect that new enforcement actions will align with the priorities articulated in the “Focus, Fairness, and Efficiency in the fight Against White-Collar Crime” memo, which we discussed in a previous alert.
• Faster investigations: With more resources devoted to health care fraud, more communication among agencies, and more emphasis from the DOJ on efficient prosecution, we may see investigations reach a conclusion more quickly.
• State and Federal partnerships: The announcement of the Strike Force’s partnership with the Medicaid Fraud Control Unit of Massachusetts (also known as the Medicaid Fraud Division of the Massachusetts Attorney General’s Office) could lead to more federal intervention in state-initiated investigations (and vice versa).

How Hogan Lovells can help

Our litigation team in the Hogan Lovells Boston office – which includes former federal health care prosecutors from the Office – has vast experience litigating health care fraud cases in the District of Massachusetts and with the Attorney General’s Office. With our team’s firsthand understanding of the courts, the State and Federal enforcement authorities, and the industry, we are well-positioned to help clients prepare for and respond to the potential uptick in investigations and enforcement actions coming out of the Strike Force expansion. We stand ready to help companies evaluate their compliance policies in light of new developments and to respond in the event of a government inquiry.

Authored by Maria R. Durant, Anthony E. Fuller, and Greg F. Noonan.