On June 30, 2025, the U.S. Department of Justice (“DOJ”), together with the U.S. Department of Health and Human Services Office of Inspector General (“HHS OIG”) and other law enforcement partners, announced the results of the 2025 National Health Care Fraud Takedown—hailed as the largest in history.

This year, DOJ’s Health Care Fraud Unit reported that 324 defendants were charged for their alleged involvement in various health care fraud schemes that involved over $14.6 billion in intended loss—more than doubling the prior record of $6 billion set in 2020 during the first Trump administration. By way of comparison, last year, the 2024 Takedown charged 193 defendants with allegedly committing more than $2.5 billion in fraud. And two years ago, the 2023 Takedown charged 78 defendants with more than $2.5 billion. To say there was a significant increase between the Biden administration and the second Trump administration would be an understatement.

That this administration would “follow the money” should not come as a surprise. As noted, the prior record was set during President Trump’s first term in 2020. In that Takedown, DOJ and HHS OIG reported 345 defendants allegedly submitted more than $6 billion in false and fraudulent claims to federal health care programs and private payers. The bulk of that 2020 Takedown, $4.5 billion, was related to telehealth.

A repeated message of DOJ in the second Trump administration has been targeting fraud, waste, and abuse in health care. As Matthew Galiotti, head of the DOJ’s criminal division said, “Today’s enforcement action represents the largest healthcare fraud takedown in American history but it’s not the end…It’s the beginning of a new era of aggressive prosecution and data-driven prevention.”

In connection with the Takedown, Galiotti also announced a new collaboration between the Federal Bureau of Investigation (“FBI”), HHS OIG, and other federal agencies to create a Health Care Data Fusion Center (“Fusion Center”) aimed at revolutionizing the detection, investigation, and prosecution of health care fraud. Led by the DOJ’s Health Care Fraud Unit and comprised of data specialists from the unit's data analytics team, the Fusion Center “will break down information silos using coordinated data analysis, to enable our investigative teams to quickly identify and dismantle emerging fraud schemes.”

Health care companies have effectively been put on notice that the industry will continue to be a top enforcement priority for federal law enforcement efforts, so we expect to see similar figures over the course of the coming years. Furthermore, as DOJ increasingly relies on data analytics, we expect to see many investigations predicated upon health care providers who are billing outliers.

What Has Stayed the Same and What Has Changed?

In the second Trump administration, the 2025 DOJ is back to calling this a “takedown”—as opposed to an “enforcement action,” a Biden-era term. Whether this terminology change is due to its aggressive connotations or not, the scope of the takedown cannot be denied.

The 2025 Takedown operated on a global scale, with 29 defendants in transnational criminal organizations alleged to have submitted more than $12 billion in fraudulent claims to U.S. health insurance programs. Charges against 19 defendants stemmed from an investigation called Operation Gold Rush—a network of foreign straw owners who allegedly bought U.S. medical supply companies; submitted $10.6 billion in fraudulent claims to Medicare (using the stolen identities of U.S. citizens); and laundered the proceeds. Another foreign scheme involved five defendants who allegedly used artificial intelligence (“AI”) to create fake recordings of Medicare beneficiaries consenting to products and services.

As has been the case in the past, the health care fraud enforcement efforts in 2025 led to the seizure of many assets, including more than $245 million in cash, luxury vehicles and cryptocurrency. Interestingly, despite the massive increase in intended loss, this seizure is on a par with 2024, where the government reportedly seized $231 million worth of cash, cars, and gold.

One of the more interesting aspects to this year’s takedown is the inclusion of civil enforcement actions. The 2025 Takedown includes civil charges against 20 defendants for $14.2 million in alleged fraud and civil settlements with 106 defendants totaling $34.3 million. While the approximately $50 million in civil recoveries pales in comparison to the intended loss figure from the criminal enforcement, these are monies that the government either has or will likely recoup. As we have previously noted, civil cases typically involve larger corporations and more substantial financial recoveries than criminal enforcement. It is possible that emphasis on civil recoveries will become standard in future takedowns.

As for the Fusion Center, while it may be new, the Health Care Fraud Unit has been using data analytics for more than 15 years. Crunching data allows it to try to keep pace with constantly evolving fraud schemes: “Although health care fraud enforcement is necessarily reactive (and not proactive), DOJ hopes that its increasing use of data analytics will help it break the cycle of ‘pay and chase.’”

Types of Cases in this Year’s “Takedown”

This year’s Takedown is grouped into four categories of cases, down from six in 2024, although the topics remain largely the same. The 2025 cases involved:

Fraudulent wound care. The DOJ announced eight different cases involving various wound care schemes, including one case that involved seven defendants, five of whom are medical professionals, that were charged in connection with approximately $1.1 billion in allegedly fraudulent claims to Medicare and other health care benefit programs.

Prescription opioid trafficking. Seventy-four defendants, including 44 medical professionals, were charged in 58 cases for the alleged diversion of more than 15 million pills of prescription opioids and other controlled substances. Within the past six months, the Drug Enforcement Administration (“DEA”) has charged 93 administrative cases relating to the revocation of the authority to handle and/or prescribe controlled substances.

Telemedicine and genetic testing fraud. Forty-nine defendants were charged with allegedly submitting $1.17 billion in fraudulent claims to Medicare resulting from telemedicine and genetic testing. Importantly, DOJ noted that it will continue to focus on fraudulent claims related to genetic testing, durable medical equipment and COVID-19 tests, all of which have been of interest to the DOJ for at least the past five years—see, e.g., Operation Brace Yourself and Operation Double Helix.

Other health fraud schemes. One hundred seventy defendants were charged with more than $1.84 billion in allegedly false and fraudulent claims to Medicare, Medicaid, and private insurance companies regarding treatments and services that were medically unnecessary, not provided at all, or provided in connection with kickbacks and bribes.

‘Largest Target of All’

In addition to HHS OIG and the FBI, the DOJ partnered with CMS, DEA, and other enforcement agencies, including Medicaid Fraud Control Units (“MFCUs”) (see EBG’s recent blog post) for the 2025 Takedown.

As CMS Administrator Dr. Mehmet Oz noted, CMS is “probably the largest target of all, responsible for about $ 1.7 trillion dollars of disbursements.” CMS further announced on June 30 that it has successfully prevented more than $4 billion from being paid—and had suspended or revoked the billing privileges of 205 providers in the months leading up to the 2025 Takedown.

“They can pierce the veil of protection by just getting identifier numbers from our seniors or Medicaid recipients or others and thus use those tools…to hurt us,” Oz said. “What we’re doing today is changing the paradigm—not just going after bad guys and putting them behind bars but actually getting ahead of these schemes so the money never leaves our bank account.”

Takeaways

As always, these kinds of enforcement actions remind those who are involved in health care— whether as a practitioner, in the C-Suite, or elsewhere in the field—that appropriate compliance programs and general oversight remain critical. The 2025 Takedown confirms, however, that now more than ever, DOJ under Attorney General Pam Bondi will be aggressively focused on investigating, prosecuting, and preventing health care fraud, whether to address patient harm, stem the opioid epidemic and/or return money to government coffers—as President Trump and the agency have consistently said that they would.

We will continue to monitor these annual enforcement actions and other developments in this space.

Chart of Cases Filed in Federal and State Court

(Alphabetical by State)

Epstein Becker Green Staff Attorney Ann W. Parks contributed to the preparation of this post.