A new report from the Financial Crimes Enforcement Network (FinCEN) identifying $17.5 billion in suspected healthcare fraud in the past year is the latest signal that combating healthcare fraud will remain a significant priority for the federal government, reinforcing a consistent message from the current administration. 

On September 9, 2026, FinCEN, part of the U.S. Department of the Treasury, released a Financial Trend Analysis that identified approximately $17.5 billion in suspicious activity linked to potential healthcare fraud based on review of approximately 5,700 Bank Secrecy Act (BSA) filings submitted by financial institutions between March 1, 2025, and February 28, 2026. Treasury characterized the analysis as part of the administration's broader effort to combat fraud, protect federal healthcare programs, and strengthen coordination among financial institutions and law enforcement agencies. Healthcare fraud was listed as a top priority of the Department of Justice's (DOJ) Criminal Division in its May 2025 memorandum regarding combating white collar crime. And in August 2026, the DOJ's National Fraud Enforcement Division issued a memorandum describing healthcare fraud as one of the division's top enforcement priorities, saying that the division would use "cutting-edge data analysis to target exploitative health care fraud schemes."

Healthcare providers, home healthcare companies, addiction treatment centers, medical device companies, and other participants in federally funded healthcare programs should expect heightened scrutiny of payment flows and billing practices.

The Financial Trend Analysis

According to FinCEN's analysis: 

• Potential fraud schemes involved payments from Medicare, Medicaid, and private insurers and often involved multiple reimbursement sources. 
• The most frequently identified entities were home healthcare businesses, which accounted for more than 21 percent of the reviewed reports. Hospice providers, behavioral health and addiction treatment providers, medical equipment suppliers, and daycare providers also appeared frequently in the suspicious activity reports. The analysis also cited a large number of BSA reports related to eligibility for Medicaid in Puerto Rico. 
• The level of sophistication in the fraud schemes varied widely from individuals targeting a single healthcare program to networks of entities, including shell companies, being used to target multiple healthcare programs. The majority of the BSA reports, according to the analysis, involved purported healthcare providers that did not appear to offer any medical services. However, the reports also described activity of seemingly legitimate medical providers engaging in fraudulent billing practices, accepting kickbacks, or providing medically unnecessary services. 
• Though the proceeds of suspected healthcare fraud are primarily sent and spent within the U.S., FinCEN also identified funds sent to 32 countries around the world. The most frequent foreign recipient was Hong Kong, but Canada, Mexico, Nigeria, Pakistan, China, the Philippines, Türkiye, and the United Arab Emirates were also common recipients. 

What This Means for Healthcare Enforcement

The most significant takeaway from the FinCEN analysis may be what it reveals about the government's evolving enforcement toolkit rather than the specific conduct or dollar amounts identified. Historically, healthcare fraud investigations frequently began with billing outliers, audits, patient complaints, or whistleblower allegations. Treasury's announcement reflects the federal government's ability to supplement those traditional methods with data analytics of financial intelligence generated by banks and other financial institutions. As a result, investigators may be able to identify potential fraud schemes not only through healthcare claims data but also through records of unusual payment activity, corporate transactions, and fund transfers.

We have discussed the administration's focus on healthcare fraud in prior alerts, which have highlighted the creation and buildout of the DOJ-Health and Human Services (HHS) False Claims Act (FCA) Working Group, the West Coast Health Care Fraud Strike Force, and the Eastern District of Pennsylvania Health Care Fraud Strike Force. The DOJ has included healthcare fraud as a top enforcement priority in both the May 2025 memorandum regarding white collar crime enforcement priorities (discussed here) and the August 2026 enforcement priorities in the National Fraud Enforcement Division memorandum. FinCEN's analysis adds another layer to that coordinated enforcement framework by highlighting how BSA reporting and FinCEN analytics can help identify potential fraud risks. 

Increased FCA Exposure

The announcement also has implications for FCA enforcement. The FinCEN findings focus on alleged suspicious financial activity rather than proven fraud. Nevertheless, where investigators identify potential connections between financial transactions and allegedly improper claims submitted to federal healthcare programs, those findings may generate or support FCA investigations.

In the announcement regarding the analysis, Treasury expressly encouraged whistleblowers to report credible information related to fraud, saying, "[t]ips from whistleblowers, combined with financial institutions' BSA reporting, can help Treasury and its law enforcement partners uncover criminal networks, recover taxpayer funds, and hold bad actors accountable." Healthcare entities should expect continued cooperation among agencies and continued efforts to leverage whistleblower allegations alongside financial and claims data. 

Federal enforcement authorities continue to view healthcare fraud and FCA enforcement as among their highest priorities. Organizations operating in heavily regulated healthcare sectors therefore should anticipate continued scrutiny of both reimbursement practices and underlying financial activity. 

Compliance Considerations

In light of Treasury's announcement, healthcare organizations and related entities should review their compliance programs and internal controls to ensure they adequately address the risks at the intersection of reimbursement practices, financial controls, and fraud-risk management. Areas warranting particular attention include:

• Billing and coding controls related to Medicare, Medicaid, and other government healthcare programs
• Monitoring of unusual payment patterns or reimbursement anomalies
• Financial controls governing vendor payments, related-party transactions, and international transfers
• Internal reporting and investigation mechanisms for receiving and reviewing allegations of fraud or misconduct
• Documentation supporting medical necessity, reimbursement decisions, and claims submission practices
• Risk assessments focused on business lines identified by Treasury as presenting elevated enforcement risk, including home health, hospice, behavioral health, addiction-treatment services, and durable medical equipment

Looking Ahead

The FinCEN Financial Trend Analysis reinforces a broader federal enforcement trend: healthcare fraud investigations are an administration priority and are increasingly driven by data aggregation, financial intelligence, and interagency coordination. The use of BSA reporting to identify potential healthcare fraud demonstrates that enforcement authorities are drawing information from sources that extend well beyond the traditional sources of claims databases and audits.

Organizations receiving federal healthcare funds should anticipate continued collaboration among Treasury, FinCEN, DOJ, HHS' Office of the Inspector General (HHS-OIG), and other enforcement agencies. Coupled with ongoing FCA enforcement initiatives and continued encouragement of whistleblower reporting, FinCEN's report suggests that healthcare fraud enforcement will remain a top enforcement focus for the foreseeable future. 

For more information, please contact:

Joshua Drew, jdrew@milchev.com, 202-626-5811

Ian A. Herbert, iherbert@milchev.com, 202-626-1496

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