OCR Restructuring To Strengthen Rights of Conscience and Religious Freedom Rights Oversight and Enforcement

May 20, 2026

The U.S. Department of Health and Human Services (HHS) May 18, 2026 announcement of its reorganization of its Office for Civil Rights (OCR) signals employer and other health plan sponsors, health care providers and others funded or regulated by HHS experiencing discrimination or other conflicts with conscience or religious objections may expect greater protection from HHS, even as it warns federal health care exchange, Medicare and Medicaid Advantage health plans, and other health payers; health care providers; housing and education providers, states and other organizations and individuals receiving HHS funding to ensure their practices and policies comply with current HHS policies on federal conscience and religious freedom rights.

The reorganization of the HHS agency charged with enforcing HHS-administered laws protecting civil rights, conscience and religious freedom, and health information privacy and security, returns OCR to a program-based structure that reelevates conscience and religious freedom protection enforcement by realigning OCR into three distinct subject-matter divisions:

  • The Conscience and Religious Freedom Division,responsible for enfocing federal rights of conscience and religious freedom;
  • The Civil Rights Division, responsible for enforcing Section 1557 and other civil rights and disability laws implemented and enforced by HSS; and
  • The Health Information Privacy, Data, and Cybersecurity Division, responsible for implementing and enforcing the privacy, data security, data breach and privacy rights of the Health Insurance Portability and Accountability Act of 1996 (HIPAA), the Genetic Information Nondiscrimination Act (GINA) and other privacy and data security requirements implemented and enforced by HHS.

Historical Background Leading To Reorganization

HHS originally established a separate OCR Conscience and Religious Freedom Division (CRFD) to handle federal enforcement of the nation’s laws that protect the rights of conscience and religious freedom protected under the United States Constitution and other federal laws in January 2018 during President Trump’s first presidency. That division enforced and raised public awareness of conscience and religious freedom laws in health and human services, underscoring that violations are serious infractions that transgress basic human dignity and fundamental rights.

CRFD operated until March of 2023, when the Biden administration dissolved the division in 2023. Although OCR maintained jurisdiction over conscience and religious freedom authorities in health and human services after 2023, the Biden Administration combined the Conscience and Religious Freedom Division and the then-Civil Rights Division into the Policy Division.

According to the announcement, the intake and processing of complaints filed with OCR, and the review of reported breaches involving unsecured protected health information, will continue to be handled by an Enforcement Division that supports centralized intake and field-office execution. The reorganization is not expected to result in a reduction of OCR’s workforce.The OCR reorganization announcement reports OCR will publish more information about the reorganization in a Federal Register notice next month. Scribe and stay tuned for more developments.

Reorganization Part of HHS Actions To Enhance Conscience Rights and Religious Freedom Protections

OCR intends for the reorganization to strengthen its enhanced efforts to protect federal rights of conscience and religious freedom undertaken in response to Trump Administration directives. OCR’s announcement responds builds upon the Trump Administration policy and HHS’ resulting recent efforts to enforce federally protected right of conscience protections and protect human life. 

Since President Trump began his second administration, he has made protection of rights of conscience, freedom of religion and protection of human life policy priorities. See  Fact Sheet: HHS Takes Comprehensive Action to Enforce Conscience Rights and Protect Human Life, and OCR’s conscience and religious freedom webpage. Since returning to office in January 2025, President Trump has issued several executive orders and presidential directives designed to expand protections for religious liberty, conscience rights, and faith-based participation in federal programs since beginning his second term in office by among other things:

  • Establishing the White House Faith Office within the Executive Office of the President and ordering all executive agencies to protect religious liberty, coordinate with faith-based organizations, and identify barriers affecting religious groups seeking participation in federal programs under Executive Order 14205;
  • Creating a federal “Task Force to Eradicate Anti-Christian Bias,” led by the Department of Justice and involving multiple agencies charged with reviewing federal policies, investigations, and enforcement activities allegedly discriminating against Christians or religious organizations. DOJ Task Force Report on Anti-Christian Bias and Religious Liberty;
  • Establishing the Religious Liberty Commission, declaring it federal policy to “vigorously enforce” protections for religious liberty under federal law, and directing the Commission to study threats to and recommend safeguards for religious exercise including conscience protections, free exercise rights, religious education, and the role of faith-based organizations in public life under Executive Order 14291; and
  • Proclaiming January 26. 2026, Religious Freedom Day, 2026.

OCR’s announced restructuring is part of a broader set of activities OCR is undertaking to strengthen its oversight and enforcement of conscience and religious freedom rights in response to these Trump Administration directives. Before announcing the restructuring, OCR already has taken enforcement action to protect health care workers, support whistleblowers, and reinforce adherence to religious and conscience exemptions in the Vaccines for Children Program as part of these policies. For example, OCR previously has:

  • Repudiated a 2021 Biden Administration era letter that excluded employers and plan sponsors from the scope of health care entities protected by the Weldon Amendment and notified states and other regulated entities no longer rely on the now-repudiated legal position;
  • Repudiated other Biden Administration era policies on reproductive rights, diversity equity and inclusion and other policies considered outdated or inconsistent with the Trump Administration’s interpretation of federal conscience and religious freedom rights;
  • Issued public notices describing OCR deregulatory actions to align with President Trump’s E.O. 14182, Enforcing the Hyde Amendment;
  • Issued a nationwide Dear Colleague Letter explaining OCR’s right of conscious policy under the Trump Administration;
  • Issued a Notice of Violation that found an Illinois state law violated the Weldon and the Coats-Snowe Amendments, which are among two dozen federal health care conscience protection statutes that HHS enforces. The Illinois Notice of Violation charges the Illinois law unlawfully ties health care provider conscience protections to referral requirements in the case of abortion;
  • OCR announced its investigation of 13 states for allegedly violating the Weldon Amendment federal health care conscience law by coercing health care entities, health insurers, and employers and their health plans to provide coverage of, or pay for, abortion contrary to conscience;
  • To educate the public, OCR also released a nationwide Dear Colleague Letter summarizing federal health care conscience protection statutes, including those laws specific to abortion, sterilization, and assisted suicide; and
  • Undertaken high profile investigations and enforcement actions against academic medicine and other health, education or other HHS funding recipients perceived to have discriminated or violated rights of conscience or religious freedoms of individuals of Christian or Jewish faith.

OCR’s announcement of the reorganization makes clear it intends for the reorganization to strengthen its ability to enforce these and other interpretations and policies for the protection and defense of rights of conscience and religious freedom in accordance with the Trump Administration directives. The announcement quotes HHS Office for Civil Rights Director Paula M. Stannard as saying, “This reorganization reinstitutes a structure that rightly prioritizes civil rights and conscience and religious freedom alongside health information privacy and security,” and that “All three areas are deserving of subject-matter expertise and distinct senior executive leadership for OCR to best serve the American people.” HHS’ announcement also states the reorganized structure will improve OCR’s effectiveness and efficiency to advance the protection of conscience rights, address race-based discrimination in a color-blind manner, eradicate antisemitism and anti-Christian bias, and restore biological truth.

Given the current emphasis of OCR and other federal agencies on protection and enforcement of federally protected rights of conscience and religious freedom under current Trump Administration policies, employers, health care providers, health insurers and plans, academic medicine and other education, housing and other entities funded or participating in HHS programs specifically should contact qualified legal counsel for assistance in evaluating and ensuring that their policies and procedures properly align with OCR right of conscience and religious freedom enforcement policies. Along with generally reviewing policies or practices that might raise right of conscience or religious discrimination or freedom concerns, these entities also should tread carefully and seek the assistance of legal counsel with identifying and responding to requests or other potential right of conscience, religious discrimination, or religious freedom concerns arising in their dealings with employees, service providers, customers and others.

Meanwhile employer and other plan sponsors and other organizations that feel that they are suffering discrimination or other violations of their rights of conscience or religious freedom may wish to evaluate their ability to secure accommodations or other relief under the religious freedom and right of conscience policies from HHS or other applicable federal agencies, the courts, or both.

For Help or More Information

The author of this update, Cynthia Marcotte Stamer has decades of experience advising and assisting health industry clients to design, audit, and defend their organizations and practices including conducting audits and investigations, designing and updating compliance and risk management programs, responding to government investigations, conducting transaction, governance, and other due diligence, and assisting with other legal and operational compliance and risk management and legislative and regulatory affairs. She is available to assist your organization in assessing the impact of these developments and navigating the compliance and strategic steps that follow. For more information about these or other health care, managed care and other health benefits, or other health industry laws or concerns, contact Ms. Stamer via e-mail or via telephone at (214) 452 -8297.

About the Author

Cynthia Marcotte Stamer is an American College of Employee Benefits Counsel and a Martindale-Hubble “AV-Preeminent” (Top 1%) attorney and advisor board certified in labor and employment law by the Texas Board of Legal Specialization peer peer celebrated as “Top Rated Lawyer” and “LEGAL LEADER™ “Top Rated Lawyer” and “Best Lawyer” for her work in ERISA & Employee Benefits Law, Health Care Law, Labor and Employment Law, and Business and Commercial Law.

Nationally recognised for her decades of leading edge health and other employee benefits and insurance, compensation, human resources and other management work, public policy leadership and advocacy, coaching, teachings, and publications, Ms. Stamer is well known for her decades of pragmatic, leading edge work, scholarship and thought leadership on health benefit and other health and managed care, privacy and data security and other employee benefit, insurance, and health industry legal, public policy and operational concerns. 

Ms. Stamer’s work throughout her career has focused heavily on working with health care and managed care, health and other employee benefit plan, insurance and financial services and other public and private organizations and their technology, data, and other service providers and advisors domestically and internationally with legal and operational compliance and risk management, performance and workforce management, regulatory and public policy and other legal and operational concerns.  As a a key focus of this work, she has continuously and extensively worked with domestic and international health plans, their sponsors, fiduciaries, administrators, and insurers; managed care and insurance organizations; third party administrators and other health benefit service providers; hospitals, health care systems and other health care providers, accreditation, peer review and quality committees and organizations; billing, utilization management, management services organizations, group purchasing organizations; pharmaceutical, pharmacy, and prescription benefit management and organizations; consultants; investors; EMR, claims, payroll and other technology, billing and reimbursement and other services and product vendors; products and solutions consultants and developers; investors; managed care organizations, self-insured health and other employee benefit plans, their sponsors, fiduciaries, administrators and service providers, insurers and other payers, health industry advocacy and other service providers and groups and other health and managed care industry clients as well as federal and state legislative, regulatory, investigatory and enforcement bodies and agencies.

Her experience includes more than 35 years of leading edge work for employer and other plan sponsors, plans and their fiduciaries, insurers, third party administrators, health care clearinghouses and other health care, insurance and other data and technology providers, and others on health and other employee benefits design, administration, compliance, and policy including decades of work on fiduciary compliance and risk management; eligibility, coverage and other plan mandates; administrative simplification and transparency; PBM, pharmacy and pharmaceutical management and regulation; surprise billing and other non-par provider; direct provider, vendor and other credentialing, contracting and management; and other managed care and insurance; high deductible, minimum or level premium, captive and other non traditional funding; and agency and private audits, investigations and enforcement; and other insured and self-insured health benefit contracting, design, administration, regulation, fiduciary and other liability managment, and other design, compliance, risk management, defense, and operations solutions.

She also has extensive experience helping health care systems and organizations, group and individual health care providers, health plans and insurers, health IT, life sciences and other health industry clients prevent, investigate, manage and resolve  sexual assault, abuse, harassment and other organizational, provider and employee misconduct and other performance and behavior; manage Section 1557, Section 504, Civil Rights Act and other discrimination and accommodation, and other regulatory, contractual and other compliance; vendors and suppliers; contracting and other terms of participation, medical billing, reimbursement, claims administration and coordination, Medicare, Medicaid, CHIP, Medicare/Medicaid Advantage, ERISA and other payers and other provider-payer relations, contracting, compliance and enforcement; Form 990 and other nonprofit and tax-exemption; fundraising, investors, joint venture, and other business partners; quality and other performance measurement, management, discipline and reporting; physician and other workforce recruiting, performance management, peer review and other investigations and discipline, wage and hour, payroll, gain-sharing and other pay-for performance and other compensation, training, outsourcing and other human resources and workforce matters; board, medical staff and other governance; strategic planning, process and quality improvement; meaningful use, EMR, HIPAA and other technology,  data security and breach and other health IT and data; STARK, ant kickback, insurance, and other fraud prevention, investigation, defense and enforcement; audits, investigations, and enforcement actions; trade secrets and other intellectual property; crisis preparedness and response; internal, government and third-party licensure, credentialing, accreditation, HCQIA and other peer review and quality reporting, audits, investigations, enforcement and defense; patient relations and care;  internal controls and regulatory compliance; payer-provider, provider-provider, vendor, patient, governmental and community relations; facilities, practice, products and other sales, mergers, acquisitions and other business and commercial transactions; government procurement and contracting; grants; tax-exemption and not-for-profit; privacy and data security; training; risk and change management; regulatory affairs and public policy; process, product and service improvement, development and innovation, and other legal and operational compliance and risk management, government and regulatory affairs and operations concerns. to establish, administer and defend workforce and staffing, quality, and other compliance, risk management and operational practices, policies and actions; comply with requirements; investigate and respond to Department of Insurance, Board of Medicine, Health, Nursing, Pharmacy, Chiropractic, trucking, alcohol and firearm, and other licensing agencies, Department of Aging & Disability, FDA, Drug Enforcement Agency, OCR Privacy and Civil Rights, Department of Labor, IRS, HHS, DOD, FTC, SEC, CDC and other public health, Department of Justice and state attorneys’ general and other federal and state agencies; JCHO and other accreditation and quality organizations; private litigation and other federal and state health care industry actions: regulatory and public policy advocacy; training and discipline; enforcement;  and other strategic and operational concerns.

Former lead advisor to the Government of Bolivia on its Social Security Privatization reform, miss Stamer also has extensive legislative and regulatory affairs experience on federal, state and international employee benefits, healthcare, workforce, education, insurance, data privacy and security, antitrust, and other regulations and reforms.

In addition, Ms. Stamer contributes her time and leadership to numerous policy, professional, civil and other organizations, Ms. Stamer currently or previously served as the Scribe leading annual agency meetings on HIPAA and other issues with the Department of Health and Human Services; leadership Council Representative, speaker, author and faculty lead for the American Bar Association (“ABA”) Joint Committee on Employee Benefits; the ABA International Section International Employment Law Committee and International Life Sciences Committee Chair; the ABA Tort Trial and Insurance Practice Section Medicine and Law Committee Chair and Employee Benefits and Worker’s Compensation Committees Vice Chair; the ABA Health Law Section Managed Care & Insurance Interest Group Chair and Risk Management Interest Group Chair; the ABA RPTE Employee Benefits & Other Compensation Group Chair and Welfare Benefit, Fiduciary Responsibility, and Plan Terminations and Transactions Committees Chair; Vice President and Executive Director of the North Texas Health Care Compliance Professionals Association; a Southwest Benefits Association Board Member; a SHRM Consultants National and Region IV Board Chair; WEB National Board Member and Dallas Chapter President; National Kidney Foundation of North Texas Board Member and Compliance Chair; Richardson Development Center (now Warren Center) for Children Early Childhood Intervention Agency Board President; a North Texas United Way Long Range Planning Committee Member; and other leadership involvement in a broad range of other professional and civic organizations.

Author of hundreds of highly regarded works on health and other benefits, human resources, health care, insurance, data privacy and security and other related concerns, examples of these publications include “Transparent PBM Contracting,” “ACOs, Direct Contracting: Legal & Practical Challenges For Employers, Providers & TPAs,” “The Medicare Advantage Contracting Manual,” “Third Party Administrator (TPA) Contracting Principles and Strategies and a multitude of other publications and presentations. 

For more information about Ms. Stamer or her health industry and other experience and involvements, see www.cynthiastamer.com or contact Ms. Stamer via telephone at (214) 452-8297 or via e-mail here.

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$17M IBM Settlement Adds DOJ False Claims Act Liability To Risks For Using DEI Practices

April 20, 2026

The $17 million False Claims Act settlement with technology giant IBM by announced April 10, 2026, using affirmative action or other disfavored diversity, equity and inclusion (“DEI”) practices creates added risks for federal government contractors and grant recipients beyond those U.S. businesses as a whole already face under the Trump Administration “merit based” interpretation and enforcement of federal Civil Rights laws as prohibiting DEI or other discriminatory decision making.

In the face of the IBM and other agency investigations and enforcements under the new merit based civil rights policy, all US businesses, generally, and government contractor specifically should seek the advice of qualified legal counsel on their potential exposure and options for mitigation of their exposure under the Trump merit based Civil Rights law interpretation and enforcement policy.

Affirmative Action & Other DEI Practices Under Attack

Government and private DEI practices have faced increasing challenges under a series of Supreme Court rulings that interpret the 14th Amendment as prohibiting affirmative action and other government required or applied race based hiring and other preferences except where adopted and tailored to redress a proven specific past discrimination harm. See e.g., Students for Fair Admissions v. President and Fellows of Harvard College, 600 U.S. ___ (2023); Adarand Constructors, Inc. v. Peña, 515 U.S. 200 (1995); Ricci v. DeStefano, 557 U.S. 557, 579–80 (2009). While the Court rulings since as early as 2009 indicated racial or other DEI preferences were allowed only to redress a past history of discrimination, federal regulators and many courts applied these holdings in a manner that presumed or required little evidence of specific discrimination to uphold DEI practices. Consequently, federal regulations and enforcement encouraged if not required broad adoption of these practices for decades.

The Supreme Court cast the dye for change with its ruling in Students for Fair Admissions, that race-conscious admissions programs at Harvard University and the University of North Carolina violated the Equal Protection Clause and, as applied to recipients of federal funds, Title VI of the Civil Rights Act of 1964 (42 U.S.C. § 2000d). Rejecting the universities’ diversity rationales as insufficiently measurable and not narrowly tailored, the Supreme Court in Students for Fair Admissions ruled that racial classifications are presumptively invalid and must meet strict scrutiny with clear endpoints and individualized consideration to overcome that presumption of invalidity. Its holding and reasoning as applied to the facts leave little room for legal defense of DEI practices in education, government contracting, employment and other practices historically using DEI strategies absent a specific remedial justification tied to proven discrimination. See also Ricci v. DeStefano, 557 U.S. 557 (2009).

President Trump reacted to the Students for Fair Admissions and other Supreme Court rulings banning DEI policies in a series of Executive Orders upon beginning his second Presidency. See, Exec. Order No. 14148, Ending Radical and Wasteful Government DEI Programs and Preferencing, 90 Fed. Reg. ___ (Jan. 20, 2025); Exec. Order No. 14149, Restoring Merit-Based Opportunity and Ending Illegal Discrimination, 90 Fed. Reg. ___ (Jan. 20, 2025); Office of Mgmt. & Budget, Memorandum M-25-13, Initial Guidance Regarding President Trump’s Executive Order on Ending DEI Programs (Jan. 21, 2025); U.S. Office of Personnel Mgmt., Guidance on Implementation of Executive Orders Eliminating DEI Programs in Federal Workforce (Jan. 2025); U.S. Dep’t of Justice, Memorandum on Civil Rights Enforcement and Prohibition of Race-Based Preferences (Jan. 2025); U.S. Dep’t of Defense, Directive on Removal of Diversity, Equity, and Inclusion Training and Programs (Feb. 2025); U.S. Dep’t of Educ., Dear Colleague Letter, Application of Federal Civil Rights Laws to Race-Conscious Policies Post-SFFA (Feb. 2025).

Upon taking office, President Trump in his January 21, 2025 Executive Order 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity (“EO 14173”) directed federal agencies to interpret and enforce the Civil Rights Act as requiring merit-based decisions without application of preferences for diversity, equity and inclusion,” (“DEI”), “affirmative action” or other favoritism to particular groups.

In Executive Order (“EO”) 14173, President Trump announced his interpretation of the equal protection and opportunity provision of the 14th Amendment of the U.S. Constitution, the Civil Rights Act of 1964 (“Civil Rights Act “), Section 1557 of the Patient Protection and Affordable Care Act of 1996 (“Section 1557”) and other federal civil rights laws as guaranteeing “merit-based” decision-making and prohibiting DEI, affirmative action and other non-merit-based race, sex, religious, national origin preferences. Consistent with this merit-based construction, President Trump ordered all federal agencies “to terminate all discriminatory and illegal preferences, mandates, policies, programs, activities, guidance, regulations, enforcement actions, consent orders, and requirements” and “to enforce our longstanding civil-rights laws and to combat illegal private-sector DEI preferences, mandates, policies, programs, and activities.”

On April 23, 2025, President Trump followed up on EO 14173 by ordering all federal agencies to stop treating disparate impact as a viable theory of liability in discrimination matters in Executive Order on Restoring Equality of Opportunity and Meritocracy.

In response to these directives, federal agencies abandoned decades of regulations and enforcement practices that encouraged if not required DEI practices to enforce a merit based decision making interpretation of federal civil rights laws that prohibits affirmative action and other DEI practices.

In response to President Trump’s Executive Orders, for instance, the Office of Federal Contract Compliance Programs (“OFCCP”) has abandoned regulations that for decades required federal contractors to demonstrate their affirmative action requirements effectiveness with a merit-only decision policy. See, Exec. Order No. 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity, 90 Fed. Reg. 8633 (Jan. 21, 2025); U.S. Dep’t of Labor, Directive to OFCCP to Cease Enforcement of E.O. 11246 Affirmative Action Requirements (Jan. 24, 2025); Office of Federal Contract Compliance Programs, Director Catherine Eschbach, Letter to Federal Contractors Regarding Compliance with Executive Order 14173 and Wind-Down of Affirmative Action Programs (June 27, 2025); Office of Federal Contract Compliance Programs, Invitation to Voluntarily Report Compliance with Executive Order 14173 (2025).

Additionally, for employers generally, the Equal Employment Opportunity Commission (“EEOC”) revised its guidance to reflect that Title VII of the Civil Rights Act of 1964 (42 U.S.C. § 2000e-2) prohibits race-based employment decisions except in narrow circumstances, reinforcing a shift toward race-neutral strategies. See, e.g., Equal Employment Opportunity Commission, What You Should Know About DEI-Related Discrimination at Work (updated 2023–2024) (explaining that Title VII prohibits employment decisions motivated by race, even when framed as DEI initiatives). Meanwhile, the EEOC and the DOJ also sought to educate employees suffering job detriment from their employers’ DEI practices about their potential claims by jointly publishing a one-page technical assistance document, “What To Do If You Experience Discrimination Related to DEI at Work.”These actions are heightening Civil Rights discrimination risks for all employers for current or past DEI practices.

The DOJ’s weaponization of the FCA adds another significant DEI-derived risk for healthcare, education and government contractors. As reflected by a series of high profile agency actions initiated against educational and health care organizations using DEI practices announced in conjunction with or following President Trump’s DEI Executive Orders, federal health care and educational organizations participating in federal programs and federal government contractors face much greater risks from use of DEI practices beyond the general exposure of employers under the revised EEOC interpretation and enforcement policies. While initially these DEI enforcement policies targeted education and health care organizations participating in programs funded or managed by the Department of Education , the Department of Health and Human Services, or both, the IBM settlement makes clear these enforcement policies and risks now apply to federal government contractors and grant recipients as a whole.

Federal Government Contractor & Grant Recipient DEI False Claims Act Exposure

The first settlement announced by DOJ under the Civil Rights Enforcement Initiative announced in May, 2025, the IBM settlement with DOJ confirms DOJ is pursuing government contractors for using DEI practices under the False Claims Act (“FCA”).

On May 19, 2025, DOJ announced it would prosecute government contractors and other federal funds recipients under the Civil Rights Fraud Initiative for knowingly violating federal Civil Rights laws by using affirmative action, diversity, equity and inclusion, or other non-merit based (“DEI”) employment or other business preferences.

DOJ further clarified in subsequent guidance that DEI programs involving preferential treatment may violate statutes such as Title VI and Title VII, and that false certifications of compliance with those statutes may satisfy core FCA elements, including falsity and materiality. See, U.S. Dep’t of Justice, Guidance to Recipients of Federal Funding Regarding Unlawful Discrimination (July 2025).

DOJ takes the position that certain DEI programs expose federal contractors and grant recipients to liability under the FCA where those entities certify compliance with federal civil rights laws while maintaining practices the government views as involving unlawful race- or sex-based preferences.

In the Civil Rights Fraud Initiative announcement, DOJ stated that entities receiving federal funds that “knowingly violate[] federal civil rights laws” may be liable under the FCA because such violations can render certifications of compliance false and material to the government’s payment decisions. See U.S. Dep’t of Justice, Justice Department Establishes Civil Rights Fraud Initiative (May 19, 2025).

Government contractors targeted by DOJ for False Claims Act prosecution under its Civil Rights Enforcement Initiative face serious consequences as Civil Rights Act compliance is a condition of participation in federal programs. Since compliance with these requirements is a prerequisite to eligibility to bill or receive federal funds under federal programs, DOJ contends that billing the federal government or receiving funds under programs subject to these terms of participation for periods that the contractor are Grant recipient had DEI or other non-merit based practices constitutes making a false claim in violation of the False Claims Act.

Since announcing its FCA initiative, DOJ has encouraged whistleblower (qui tam) actions and signaled it was conducting active investigation and enforcement against federal funding recipients whose DEI policies allegedly conflict with federal nondiscrimination requirements of 31 U.S.C. §§ 3729–3733. See also U.S. Dep’t of Justice, Civil Division Memoranda on Civil Rights Enforcement and FCA Application (2025).

IBM Settlement Confirms DOJ FCA DEI Enforcement

The IBM settlement secured under DOJ’s Civil Rights Fraud Initiative confirms DOJ is pursuing government contractors for DEI practices.

On April 10, 2026 (publicly reported mid-April), DOJ announced that IBM agreed to pay approximately $17 million to resolve allegations that it violated the FCA by certifying compliance with federal anti-discrimination requirements in its government contracts while allegedly maintaining DEI practices that the government contended were discriminatory on the basis of race or sex. See U.S. Dep’t of Justice, IBM Pays $17 Million to Resolve Allegations of Discrimination Through Illegal DEI Practices (Apr. 10, 2026).

The DOJ IBM prosecution and resulting settlement reflect DOJ treats DEI programs as prohibited discrimination that can create FCA exposure where tied to contractual compliance obligations.

In its IBM prosecution, DOJ asserted that federal contractors must certify compliance with Title VII and related Federal Acquisition Regulation clauses as a condition of payment, and that knowingly maintaining noncompliant practices can render those certifications false and actionable under the FCA.

While IBM did not admit liability in the settlement, the DOJ sent a strong message to other government contractors to act to mediate their own exposure by repotting IBM received credit for cooperation, including early disclosures and remediation measures such as modifying or terminating the challenged programs.

As demonstrated by the announced IBM settlement, sanctions for False Claims Act violations are harsh. Along with potential criminal consequences for intentional or knowing violations, civil violations of the False Claims Act can result in treble damages and significant penalties, program exclusion or both.

Act Proactively To Mitigate Risks

The IBM settlement and other federal agency investigations and prosecutions sends a strong warning to Federal government contractors and federal grant recipients specifically and U.S. businesses generally to take proactive steps to mitigate their very real risk that their past and current DEI or other non-merit based employment and other policies.

With FCA enforcement now added to the employment discrimination enforcement risk government contractors face for challenged DEI practices, government contractors also must recognize their government contractor status puts them at a high risk of scrutiny due to the reporting and audit protocols used with government contracts and grants. When weighing the likelihood that their past or current practices will trigger scrutiny, government contractors are reminded that current and past certification and reporting facilitate the ability of DOJ and OFCCP to identify targets for enforcement under this new interpretation and enforcement of Civil Rights laws while sanctions secured through enforcement return significant revenue to federally constrained budgets.

Consequently, businesses generally and government contractors specifically should seek the assistance of qualified legal counsel to assess and mitigate their risk from past or current DEI initiatives in light of heightened litigation risk and federal agencies’s interpretation and enforcement of new Civil Rights merit based enforcement position. Organizations are encouraged to keep in mind that the sensitive nature of this investigation and analysis makes it critical that organizations conduct this analysis and their options for mitigation of liability within the scope of attorney. Client privileged to protect sensitive conversations and analysis from discovery.

If you have questions about or need assistance with these and other risk management or compliance concerns, contact the author. 

For More Information

We hope this update is helpful. For more information about the  or other health or other employee benefits, human resources, or health care developments, please contact the author Cynthia Marcotte Stamer via e-mail or via telephone at (214) 452 -8297.

Solutions Law Press, Inc. invites you receive future updates by registering on our Solutions Law Press, Inc. Website and participating and contributing to the discussions in our Solutions Law Press, Inc. LinkedIn SLP Health Care Risk Management & Operations Group, HR & Benefits Update Compliance Group, and/or Coalition for Responsible Health Care Policy.

About the Author

A Fellow in the American College of Employee Benefits Counsel and Board Certified in Labor and Employment Law by the Texas Board of Legal Certification, Cynthia Marcotte Stamer has more than 35 years experience, advising plan sponsors, fiduciaries, service providers and others about fiduciary responsibility and other employee benefit plan design, administration, risk management and compliance. i

Ms. Stamer is a Martindale-Hubble AV-Preeminent (highest/top 1%) practicing attorney recognized as a “Top Woman Lawyer,” “Top Rated Lawyer,” and “LEGAL LEADER™” in Health Care Law and Labor and Employment Law; among the “Best Lawyers In Dallas” in “Labor & Employment,” “Tax: ERISA & Employee Benefits,” “Health Care” and “Business and Commercial Law recognized for her experience, scholarship, thought leadership and advocacy on health and other employee benefits, insurance, healthcare, workforce, HIPAA and other data and technology and other compliance in connection with her work with health care and life sciences, employee benefits, insurance, education, technology and other highly regulated and performance-dependent clients.

Ms. Stamer has more than 35 plus years of experience advising and representing, employers, employee benefit plans and their fiduciaries and administrators, their administrative services, technology and other business associates and other vendors, managed care and insurance, health care and other clients about these and other workforce, employee benefits, internal controls and other operations and compliance concerns.  

Ms. Stamer is nationally sought out for her decades of leading-edge experience in the design, sponsorship, administration, and defense of health, severance, savings retirement and other employee benefit, workforce, insurance, healthcare, data and technology, and other operations to promote legal and operational compliance, reduce regulatory and other liability, and advance other operational goals. This experience includes decades of work on ERISA, Internal Revenue Code and other related labor and employment, insurance, corporate and securities, data privacy and security, licensing and other laws. She also sought out for her extensive speaking and publications on these and related concerns.

Along with her decades of legal and strategic consulting experience, Ms. Stamer also contributes her leadership and experience to many professional, civic and community organizations including current or previous service as Employee Benefits Group Chair and a Substantive Groups Committee Member for the ABA Real Property Trusts and Estates (“RPTE”) Section and Chair of its Welfare Plan, Fiduciary Responsibility and Plan Terminations Committees; Chair of the ABA International Section International Employment Law Committee; Chair and Vice Chair of the ABA Tort Trial and Insurance (“TIPS”) Section Medicine and Law Committee, Vice Chair of its Employee Benefits and Worker’s Compensation Committees; and Chair of the ABA Intellectual Property Section Law Practice Management and Special Technologies Committees; ABA Joint Committee on Employee Benefits (“JCEB”) Council Representative and Scribe for its annual agency meetings with the Department of Health and Human Services; International Section Life Sciences Committee Chair; Health Law Section Managed Care & Insurance Interest Group Chair; Vice Chair, Tax Section Fringe Benefit Committee Chair, and in various other ABA leadership capacities. Ms. Stamer also is a former Southwest Benefits Association Board Member and Continuing Education Chair, SHRM National Consultant Board Chair and Region IV Chair, Dallas Bar Association Employee Benefits Committee Chair, former Texas Association of Business State, Regional and Dallas Chapter Chair, a founding board member and Past President of the Alliance for Healthcare Excellence, as well as in the leadership of many other professional, civic and community organizations. She also is valued and celebrated for her decades of policy advocacy and charitable, pro bono, community and other service and leadership to promote understanding and strengthening health care, workforce, saving, disability, aging and retirement and other key policies and challenges through her PROJECT COPE Coalition For Patient Empowerment initiative and many other pro bono service involvements locally, nationally and internationally.

Ms. Stamer is the author of many highly regarded works published by leading professional and business publishers, the ABA, the American Health Lawyers Association, and others. Ms. Stamer also often speaks and serves on the faculty and steering committee for many ABA and other professional and industry conferences and conducts leadership and industry training for a wide range of organizations.

For more information about Ms. Stamer or her health industry, health and other benefits, workforce and other experience and involvements, see the Cynthia Marcotte Stamer P.C. website or contact Ms. Stamer via telephone at (214) 452-8297 or via e-mail here.

About Solutions Law Press™

Solutions Law Press™ provides health care, insurance, human resources and employee benefit, data and technology, regulatory and operational performance, and other business risk management, legal compliance, management effectiveness and other coaching, tools and other resources, training and education. These include extensive resources on leadership, governance, human resources, employee benefits, data security and privacy, insurance, health care and other key compliance, risk management, internal controls and operational concerns. If you find this of interest, you also be interested reviewing some of our other Solutions Law Press™ resources or training.

If you or someone else you know would like to receive future updates about developments on these and other concerns, please be sure that we have your current contact information including your preferred e-mail by creating your profile here.

NOTICE: These statements and materials are for general information and purposes only. They do not establish an attorney-client relationship, are not legal advice or an offer or commitment to provide legal advice, and do not serve as a substitute for legal advice. Readers are urged to engage competent legal counsel for consultation and representation considering the specific facts and circumstances presented in their unique circumstances at the particular time. No comment or statement in this publication is to be construed as legal advice or admission. Solutions Law Press and its authors reserve the right to qualify or retract any of these statements at any time. Likewise, the content is not tailored to any particular situation and does not necessarily address all relevant issues. Because the law constantly and often evolves, subsequent developments that could change the currency and completeness of this discussion are likely. Solutions Law Press and its authors disclaim and have no responsibility to provide any update or otherwise notify anyone of any fact or law-specific nuance, change, limitation, or other condition that might affect the suitability of reliance upon these materials or information otherwise conveyed in connection with this program. Readers may not rely upon, are solely responsible for, and assume the risk and all liabilities resulting from their use of this publication.

Circular 230 Compliance. The following disclaimer is included to ensure that we comply with U.S. Treasury Department Regulations. Any statements contained herein are not intended or written by the writer to be used, and nothing contained herein can be used by you or any other person, for the purpose of (1) avoiding penalties that may be imposed under federal tax law, or (2) promoting, marketing or recommending to another party any tax-related transaction or matter addressed herein.

©2026 Cynthia Marcotte Stamer. Non-exclusive right to republish granted to Solutions Law Press.™ For information about licensing for republication, please contact the author directly. All other rights reserved.

 

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Posted by Cynthia Marcotte Stamer

DOJ Sues Medicare Advantage Insurers & CVS Under False Claims Act & Antikickback Statute

May 5, 2025

The Department of Justice is suing three of the nation’s largest health insurance companies — Aetna Inc. and affiliates, Elevance Health Inc. (formerly known as “Anthem”), and Humana Inc., CVS Health Corporation, and three large insurance broker organizations — eHealth, Inc. and an affiliate, GoHealth, Inc., and SelectQuote Inc. for violating the False Claims Act (“FCA”) and Antikickback Statute. In the second complaint of its kind in recent months, the Justice Department complaint in ex rel. Shea v. eHealth, et al., No. 21-cv-11777 (D. Mass. May 5, 2025) accuses the defendants of paying or receiving kickbacks to steer Medicare Advantage enrollees to the defendant insurers.

Medicare Advantage Antikickback & False Claims Rules

Under the Medicare Advantage (“MA”) Program, also known as Medicare Part C, Medicare beneficiaries may choose to enroll in health care plans (MA plans) offered by private insurance companies, like defendants Aetna, Anthem, and Humana. Many Medicare beneficiaries rely on insurance brokers to help them choose an MA plan that best meets their individual needs.

Under the FCA, private parties can file an action on behalf of the United States and receive a portion of the recovery. The FCA permits the United States to intervene in and take over the action, as it has done here. If a defendant is found liable for violating the FCA, the United States may recover three times the amount of its losses plus applicable penalties

In a lawsuit originally filed by a former eHealth employee as a qui tam whistleblower complaint, the Justice Department charges that the defendant insurers paid hundreds of millions of dollars in illegal kickbacks to the defendant brokers in exchange for enrollments into the insurers’ Medicare Advantage plans from 2016 through at least 2021. Rather than acting as unbiased stewards, the Justice Department charges that the defendant brokers allegedly directed Medicare beneficiaries to the plans offered by insurers that paid brokers the most in kickbacks, regardless of the suitability of the MA plans for the beneficiaries.

According to the complaint, the broker organizations incentivized their employees and agents to sell plans based on the insurers’ kickbacks, set up teams of insurance agents who could sell only those plans, and at times refused to sell MA plans of insurers who did not pay sufficient kickbacks.

The Justice Department also alleges that Aetna and Humana each conspired with the broker defendants to discriminate against Medicare beneficiaries with disabilities whom they perceived to be less profitable. Aetna and Humana allegedly did so by threatening to withhold kickbacks to pressure brokers to enroll fewer disabled Medicare beneficiaries in their plans.

The Justice Department further alleges that, in response to these financial incentives from Aetna and Humana, the defendant brokers or their agents rejected referrals of disabled beneficiaries and strategically directed disabled beneficiaries away from Aetna and Humana plans.

Commonwealth Care Alliance Prior Kickback Settlement

The eHealth suit against the defendants is not first of its kind. In January, 2025, the Justice Department announced that MA Program insurer Commonwealth Care Alliance, Inc. (“CCA”) agreed to pay $520,355.65 to resolve allegations that Reliance HMO, Inc. (“Reliance”), a company CCA acquired in 2022, violated the FCA by providing cash payments to induce the referral of Medicare beneficiaries to enroll in Reliance’s Medicare Advantage Plan in violation of the Anti-Kickback Statute after CCA voluntarily self-disclosed the conduct to the U.S. Attorney’s Office.

In April 2019, CMS authorized Reliance to operate a MA plan for Medicare beneficiaries in Michigan, with beneficiaries receiving coverage starting in January 2020. On March 31, 2022, CCA announced the completion of its acquisition of a 70% stake in Reliance. After the acquisition, CCA identified concerns regarding certain marketing-related outreach and payments that Reliance agents had made to personnel at physician practices. In particular, CCA disclosed two schemes.

First, from April 12, 2019, through December 22, 2020, Reliance provided cash payments to healthcare professionals and administrative staff in physician practices, in exchange for providing Reliance with the contact information for patients who had agreed, through executing so-called “permission to contact” cards, to be contacted by Reliance regarding its MA plan offerings.

Second, in November 2019, prior to Reliance’s MA plan becoming active, Reliance paid each of four physicians and physician practices $2,500, which Reliance characterized as advances on “coordination of care” services to be provided by the physicians to beneficiaries when the MA plan became active in 2020.

The Justice Department alleged these payments were intended to induce the referral, recommendation, or arrangement of enrollment of Medicare beneficiaries in Reliance’s MA plan. Such payments, the United States alleges, were impermissible kickbacks in violation of the False Claims Act.

The CCA settlement resolved these charges. The settlement gave CCA credit for voluntarily self-disclosing this conduct to the Justice Department; taking remedial measures, including terminating the employees directly involved with the decision to offer the prohibited payments; and providing the United States with a detailed written statement describing its investigation, along with other supplemental information to assist the United States in its investigation.

Alleged Medicare Advantage Insurer Risk Adjustment Padding

Medicare Advantage insurers also are under investigation by the Justice Department for other alleged abuses. The Justice Department recently has investigated certain Medicare Advantage insurers for alleged manipulation of risk data to increase their capitated payments from Medicare. For Instance, the Justice Department recently sued MA Program insurer Independent Health Association and its affiliate, Independent Health Corporation (collectively, “Independent Health”) for allegedly illegally manipulating risk data used to set risk adjustment rates paid by Medicare to their Medicare Advantage plans in United States ex rel. Ross v. Independent Health Association et al., No. 12-CV-0299(S) (WDNY). To settle the litigation, Independent Health agreed to pay up to $98 million to resolve allegations that it violated the False Claims Act by knowingly submitting or causing the submission of invalid diagnosis codes to Medicare for Medicare Advantage Plan enrollees to increase payments that Independent Health received from Medicare. Under the terms of the settlement, Independent Health promised to make guaranteed payments of $34,500,000 and contingent payments of up to $63,500,000 on behalf of itself and DxID, which ceased operations in 2021. Its Chief Executive Officer separately agreed to pay $2,000,000. In addition, Independent Health entered into a five-year corporate integrity agreement (“CIA”) with HHS-OIG that requires among other things, that Independent Health hire an Independent Review Organization to annually review a sample of Independent Health’s Medicare Advantage patients’ medical records and associated internal controls to help ensure appropriate risk adjustment payments.

The Justice Department touts all of these and other investigations and enforcement actions against Medicare Advantage insurers as demonstrating its commitment to hold Medicare Advantage insurers and brokers accountable for kickbacks or other misconduct. In the Justice Department’s press release about the e-Health litigation, Deputy Assistant Attorney General Michael Granston of the Justice Department’s Civil Division. “We are committed to rooting out illegal practices by Medicare Advantage insurers and insurance brokers that undermine the interests of federal health care programs and the patients they serve.”

Risks For Insurers, Brokers, Health Plans & Fiduciaries

These and other actions send a strong warning to insurers and brokers to abstain from prohibited risk adjustment, kickbacks, or other prohibited conduct. Brokers and insurers also should keep in mind that these activities- whether in connection with the sale of Medicare Advantage or other insurance products Past history demonstrates that these activities carry risks beyond the Antikickback Statute and False Claims Act. They also can create exposures under other federal or state laws. The 2004 bid rigging prosecution of Marsh & McClennon by then New York Attorney General Elliott Spitzer is illustrative. On October 14, 2004, then New York State Attorney General Eliot Spitzer sued Marsh & McClennan and Marsh, Inc. (“Marsh”) for bid rigging and violation of various other state laws through its compensation arrangements between Marsh and several insurance companies, and bidding manipulation by Marsh. The largest U.S. insurance broker at the time, Marsh agreed in January 2005 to pay $850 million and end improper bid-rigging in a civil settlement with Spitzer. Attorney General Spitzer also brought criminal charges against individuals involved, some of which produced several guilty pleas. The last of these criminal prosecutions dragged on until 2011, when the New York Attorney General finally dismissed the remaining criminal charges against former Marsh executive marketing director William Gilman and former Marsh global placement director Edward McNenney. Marsh and others also faced charges in other states and private litigation from the scandal.

Kickbacks or other inappropriate compensation arrangements between insurers, brokers or other plan service providers also can create issues for health plan fiduciaries, sponsors, brokers and advisors. Self-insured health plan sponsors, fiduciaries, administrators and their consultants, brokers and insurers also should keep in mind that practices like those challenged in the Justice Department actions also are likely to raise concerns under the fiduciary responsibility and prohibited transaction rules of the Employee Retirement Income Security Act of 1974 (“ERISA”). Consequently, employer and other plan sponsors, their fiduciaries, and their brokers and advisors may wish to visit with experienced legal counsel about the advisability of conducting due diligence into the past, current, or future plan vendor relationships with their own programs.

The Justice Department is touting the lawsuit as an example of its commitment to hold Medicare Advantage insurers and brokers accountable for kickbacks or other misconduct. In the Justice Department’s press release about the action, Deputy Assistant Attorney General Michael Granston of the Justice Department’s Civil Division. “We are committed to rooting out illegal practices by Medicare Advantage insurers and insurance brokers that undermine the interests of federal health care programs and the patients they serve.”

 More Information Or Help

We hope this update is helpful. For more information about these or other health or other employee benefits, human resources, insurance, or health care legal developments, please contact the author, Cynthia Marcotte Stamer, via e-mail or telephone at (214) 452-8297.

Solutions Law Press, Inc. invites you to receive future updates by registering on our Solutions Law Press, Inc. Website and participating in and contributing to the discussions in our Solutions Law Press, Inc. LinkedIn SLP Health Care Risk Management & Operations Group, HR & Benefits Update Compliance Group, and/or Coalition for Responsible Health Care Policy.

About the Author

Cynthia Marcotte Stamer is a Martindale-Hubble AV-Preeminent (highest/top 1%) practicing attorney recognized as a “Top Woman Lawyer,” “Top Rated Lawyer,” and “LEGAL LEADER™” in Health Care Law and Labor and Employment Law; among the “Best Lawyers In Dallas” in “Labor & Employment,” “Tax: ERISA & Employee Benefits,” “Health Care” and “Business and Commercial Law recognized for her experience, scholarship, thought leadership and advocacy on health and other employee benefits, insurance, healthcare, workforce, HIPAA and other data and technology and other compliance in connection with her work with health care and life sciences, employee benefits, insurance, education, technology and other highly regulated and performance-dependent clients.

Board certified in labor and employment law by the Texas Board of Legal Specialization and a Fellow in the American College of Employee Benefits Counsel, Ms. Stamer is nationally recognized for her decades of leading edge experience on the design, sponsorship, administration and defense of health and other employee benefit, workforce, insurance, healthcare , data and technology and other operations to promote legal and operational compliance, reduce regulatory and other liability and promote other operational goals.

Along with her decades of legal and strategic consulting experience, Ms. Stamer also contributes her leadership and experience to many professional, civic and community organizations. She currently serves as Co-Chair of the ABA Real Property Trusts and Estates (“RPTE”) Section Welfare Plan Committee, Co-Chair of the ABA International Section International Employment Law Committee and its Annual Meeting Program Planning Committee, Chair Emeritus and Vice Chair of the ABA Tort Trial and Insurance (“TIPS”) Section Medicine and Law Committee, and Chair of the ABA Intellectual Property Section Law Practice Management Committee. She also has served as Scribe for the Joint Committee on Employee Benefits (“JCEB”) annual agency meetings with the Department of Health and Human Services and JCEB Council Representative, International Section Life Sciences Committee Chair, RPTE Section Employee Benefits Group Chair and a Substantive Groups Committee Member, Health Law Section Managed Care & Insurance Interest Group Chair, as TIPS Section Medicine and Law Committee Chair and Employee Benefits Committee and Workers Compensation Committee Vice Chair, Tax Section Fringe Benefit Committee Chair, and in various other ABA leadership capacities. Ms. Stamer also is a former Southwest Benefits Association Board Member and Continuing Education Chair, SHRM National Consultant Board Chair and Region IV Chair, Dallas Bar Association Employee Benefits Committee Chair, former Texas Association of Business State, Regional and Dallas Chapter Chair, a founding board member and Past President of the Alliance for Healthcare Excellence, as well as in the leadership of many other professional, civic and community organizations. She also is recognized for her contributions to strengthening health care policy and charitable and community service resolving health care challenges performed under PROJECT COPE Coalition For Patient Empowerment initiative and many other pro bono service involvements locally, nationally and internationally.

Ms. Stamer is the author of many highly regarded works published by leading professional and business publishers, the ABA, the American Health Lawyers Association, and others. Ms. Stamer also frequently speaks and serves on the faculty and steering committee for many ABA and other professional and industry conferences and conducts leadership and industry training for a wide range of organizations.

For more information about Ms. Stamer or her health industry and other experience and involvements, see http://www.cynthiastamer.com or contact Ms. Stamer via telephone at (214) 452-8297 or via e-mail here.

About Solutions Law Press™

Solutions Law Press™ provides health care, insurance, human resources and employee benefit, data and technology, regulatory and operational performance, and other business risk management, legal compliance, management effectiveness and other coaching, tools and other resources, training and education. These include extensive resources on leadership, governance, human resources, employee benefits, data security and privacy, insurance, health care and other key compliance, risk management, internal controls and operational concerns. If you find this of interest, you also be interested reviewing some of our other Solutions Law Press™ resources or training.

If you or someone else you know would like to receive future updates about developments on these and other concerns, please be sure that we have your current contact information including your preferred e-mail by creating your profile here.

NOTICE: These statements and materials are for general information and purposes only. They do not establish an attorney-client relationship, are not legal advice or an offer or commitment to provide legal advice, and do not serve as a substitute for legal advice. Readers are urged to engage competent legal counsel for consultation and representation considering the specific facts and circumstances presented in their unique circumstances at the particular time. No comment or statement in this publication is to be construed as legal advice or admission. Solutions Law Press and its authors reserve the right to qualify or retract any of these statements at any time. Likewise, the content is not tailored to any particular situation and does not necessarily address all relevant issues. Because the law constantly and often evolves, subsequent developments that could impact the currency and completeness of this discussion are likely. Solutions Law Press and its authors disclaim and have no responsibility to provide any update or otherwise notify anyone of any fact or law-specific nuance, change, limitation, or other condition that might affect the suitability of reliance upon these materials or information otherwise conveyed in connection with this program. Readers may not rely upon, are solely responsible for, and assume the risk and all liabilities resulting from their use of this publication.

Circular 230 Compliance. The following disclaimer is included to ensure that we comply with U.S. Treasury Department Regulations. Any statements contained herein are not intended or written by the writer to be used, and nothing contained herein can be used by you or any other person, for the purpose of (1) avoiding penalties that may be imposed under federal tax law, or (2) promoting, marketing or recommending to another party any tax-related transaction or matter addressed herein.

©2025 Cynthia Marcotte Stamer. Non-exclusive right to republish granted to Solutions Law Press.™ For information about licensing for republication, please contact the author directly. All other rights reserved.

Comments Off on DOJ Sues Medicare Advantage Insurers & CVS Under False Claims Act & Antikickback Statute | compliance, Corporate Compliance, Discrimination, false claims act, health benefit, Health Benefits, health insurance, health insurance marketplace, health plan, Health Plans, Insurance, insurance fraud, Managed Care, Medicare Advantage, pharmacy | Permalink
Posted by Cynthia Marcotte Stamer