“This Is the Beginning”: DOJ Signals Intensifying Health Care Fraud Enforcement in California

On April 2, 2026, Bill Essayli, the head of the Central District of California’s U.S. Attorney’s Office, announced a sweeping takedown and the arrests of eight defendants for $50 million in alleged fraudulent billing for hospice care. Flanked by the Administrator of the Centers for Medicare & Medicaid Services, Dr. Mehmet Oz, and Assistant Attorney General Colin McDonald, who leads the newly created National Fraud Enforcement Division, Essayli made clear that the DOJ will bring more actions against hospice and home health companies in California by proclaiming that “this is the beginning, not the end.”

Consistent with this proclamation, days later, a California man pled guilty to a $270 million health care fraud scheme, as announced by President Trump’s Task Force to Eliminate Fraud, DOJ’s Fraud Section, Essayli and the Department of Health and Human Services Office of the Inspector General (HHS-OIG). According to the plea agreement, the California man admitted to fraudulently submitting nearly $270 million in false claims over an 11-month span to California’s Medicaid program (Medi-Cal) for expensive prescription drugs that were medically unnecessary, procured by kickbacks and, in many instances, not provided to the purported patients.

State regulators have also increased enforcement. On April 9, California Attorney General (AG) Rob Bonta announced charges filed against 21 suspects and the dismantling of a major hospice fraud scheme that defrauded California out of $267 million. The announcement was made following simultaneous arrests of five people after ten different locations were searched in Southern California. Similarly, just two months prior, AG Bonta announced charges against seven individuals in connection with an alleged $3.2 million hospice fraud scheme in Monterey County, underscoring the role of parallel state enforcement.

Notably, in the past year alone in California, there have been a growing number of DOJ enforcement actions. On May 6, 2025, a man was sentenced to 12 years in prison after defrauding Medicare out of $17 million through sham hospice companies; on June 6, 2025, a nurse was indicted for fraud and aggravated theft for submitting millions in fraudulent hospice claims to Medicare; on June 23, 2025, a man pled guilty to laundering nearly $5 million in connection with a scheme to defraud Medicare out of $16 million through multiple hospice companies; on July 14, 2025, a man pled guilty to $16 million in hospice fraud; on August 5, 2025, a woman was sentenced to nine years in prison for hospice fraud; and on March 24, 2026, a woman was sentenced to nearly three years in prison for hospice fraud.

In addition to federal enforcement in California, state regulators and U.S. Attorneys’ Offices nationwide have also brought enforcement actions.

Even with the recent activity, additional arrests and expanded federal enforcement in California appear likely. In announcing the April arrests with many high-ranking federal law enforcement officials in attendance, Essayli said “this is the beginning, not the end. You’re going to see more of these charges, more arrests, more of the takedowns, you’re going to see them clustered every other month or so.” This is consistent with DOJ’s clear directive that  health care fraud is a priority of this administration, as well as .

In light of DOJ’s stated enforcement priorities, home health, hospice and skilled nursing facilities should anticipate heightened scrutiny and enforcement activity. Such matters often begin with the service of a Civil Investigative Demand or grand jury subpoena. While DOJ has historically led these efforts—often in coordination with agencies such as HHS-OIG, the FBI and the Defense Criminal Investigative Service—enforcement may also be driven by state authorities and whistleblowers.

In addition to purely government action, companies should expect increased activity from relators—private litigant whistleblowers who file lawsuits against entities that have defrauded federal programs under the False Claims Act. High-profile enforcement efforts and DOJ signaling encourages whistleblowers to bring additional claims, potentially resulting in a rise in qui tam filings under the False Claims Act and Anti-Kickback Statute.

More broadly, health care companies should be prepared for a continued increase in criminal prosecutions, including charges under 18 U.S.C. § 1347 (health care fraud).

Next Steps for Health Care Companies
DOJ stated it will increase scrutiny and enforcement around health care fraud. This is particularly true in California, which First Assistant U.S. Attorney Essayli has called a “kingdom of fraud.” Companies and executives in the hospice and home health space should act quickly to:

• Evaluate and reevaluate core risk areas—including hospice eligibility determinations, referral relationships and billing practices—to ensure controls are aligned with current enforcement priorities. DOJ guidance emphasizes that compliance programs must be tailored to a company’s specific risk profile and evolving regulatory environment.
• Refresh staff with attorney-led trainings that are specifically tailored and go beyond generic teaching, instead focusing on real-world scenarios relevant to clinicians.
• Implement systems to monitor operational and billing data for patterns that could draw scrutiny, like unusual discharge rates, referral concentrations or length of stay anomalies.
• Ensure that employees know how to raise concerns and that there are structures in place to demonstrate timely, well-documented investigations and follow-ups.
• Ensure that compliance efforts are adequately documented.

In the current environment, enforcement actions are often preceded by subpoenas, Civil Investigative Demands or whistleblower complaints. Organizations that have already conducted attorney-directed compliance reviews, implemented tailored training and documented program effectiveness are often better positioned to respond efficiently and credibly.

Thoughtful and well-documented compliance protocols and systems can also make a meaningful difference in how regulators evaluate an organization’s conduct and good faith compliance efforts. Proactive steps to implement these measures provide the best chance of creating a culture of compliance and preventing later misunderstandings, mitigating the risk of civil or criminal consequences, and ensuring proper patient care.