DOJ Fraud Declination Highlights Self-Disclosure Tradeoffs, Law360
2026年09月01日Partners Heidi Manschreck and Scott Memmott co-authored a Law360 Expert Analysis article about the US Department of Justice’s (DOJ’s) first formal healthcare fraud declination under its new departmentwide corporate enforcement policy and the considerations for healthcare organizations weighing voluntary self-disclosure.
The authors explain that while the policy offers significant incentives for companies to self-disclose, cooperate, and remediate potential misconduct, those benefits should be weighed against potential reputational, False Claims Act, and shareholder litigation risks. The article also underscores the importance of robust compliance programs and healthcare fraud–focused due diligence so investors can identify and address potential misconduct early.