California Healthcare Fraud Defense Lawyers

Are You Being Investigated or Indicted for Federal Healthcare Fraud or Medicare Fraud? We Help Uncover the Mistakes that the Government Makes When Bringing Civil and Criminal False Claims Act Charges in California. As Healthcare Fraud Defense Lawyers,We Defend and Protect Organizations and the Executives Who Run Them.

The lawyers who defend you have awarded contracts, administered them, and prosecuted fraud for the Department of Justice.

Have federal agents interviewed your staff, a subpoena or Civil Investigative Demand arrived, or Medicare stopped paying without explanation? You are probably trying to work out three things at once: how serious this is, whether you personally are exposed, and how to keep the organization running while it plays out.

It seems as though the federal government is accusing you of a crime when, at best, there may be an honest mistake made. When the DOJ or some agency issues you a civil investigative demand (CID), or a subpoena, they are coming after you and your business. They have already placed you in their scope. You do not want to talk this out with agents on your own because you know that you have done nothing wrong. This is one of the biggest mistakes made by clients.

 The decisions made in the first week shape the rest of the case, and most of the lasting damage comes from well-meant steps taken before anyone calls a lawyer.

Agents contacted us · We received a subpoena or CID · Our payments stopped

Speak with a federal defense lawyer in confidence: 1-866-601-5518 (lines open 24 hours)

Or request a call-back at a time that suits you. No case details are needed to schedule it.

California Offices — Los Angeles, California 1800 Vine St, Los Angeles, CA 90028 and 402 West Broadway, Suite #400, San Diego, California 92101.

California matters are led by Carolyn L. Oliver, a former Assistant U.S. Attorney in the Major Frauds Section of the U.S. Attorney’s Office for the Southern District of California.

This page is for healthcare owners, CEOs, CFOs, medical directors, compliance officers, and their organizations facing a federal investigation. It is not for matters brought by the California Attorney General, a county district attorney, or the Medical Board of California. Those are state matters, and we will say so if that is what you have.

What Is Healthcare Fraud?

Healthcare fraud refers to conduct where a provider, practice, facility, or individual allegedly obtains payment or benefits through false, misleading, or improper claims submitted to government healthcare programs such as Medicare, Medi‑Cal, TRICARE, Veterans Affairs, or other public or private payors.

It is treated as a serious white‑collar crime because it impacts billions of dollars of public funds and triggers enforcement under multiple federal and state statutes, including:

• The Federal False Claims Act (FCA) — civil liability for false claims, treble damages, and per‑claim penalties. 

• Anti‑Kickback Statute (AKS) — prohibits remuneration tied to referrals or billing for services. 

• Stark Law — civil penalties for improper physician self‑referrals.

Healthcare fraud can include: upcoding, unbundling, phantom billing, kickbacks, false diagnoses, medically unnecessary services, duplicate claims, and misrepresentations about treatment or equipment.

On this page: Your first questions · If payments have stopped · The next 48 hours · What your document means · When the company and its executives diverge · Los Angeles · Telemedicine and digital health · Why California is different · Attorneys · What happens when you call.

What is the Government’s Burden of Proof in a Healthcare Fraud Case?

When the government accuses you of healthcare fraud, it has to show that you engaged in a scheme to steal from a federal healthcare program, such as Medicare, DOL, Medicaid, Tricare, or another government insurance program. As seen, healthcare fraud includes various types of schemes such as:  

• Kickbacks

• Services Not Rendered

• Ghost Patients

• Inflating Cost Reports

• Lack of Medical Necessity

What to Do in the Next 48 Hours

Stop informal contact. No calls to agents, the Medicare contractor, the UPIC, or payers to “sort it out.” Route all government contact through one person: counsel.

Preserve everything. Issue a written litigation hold and turn off auto-delete on email, texts, voicemail, and records systems. Destroying or altering records can be charged under 18 U.S.C. § 1519, which carries up to 20 years, twice the maximum for health care fraud.

Leave the charts alone. No corrections, addenda, or late entries. A record improved after a subpoena becomes the government’s strongest exhibit.

Tell staff in writing that they may speak with investigators or decline, and that no one will face retaliation either way. Do not tell anyone what to say.

Notify your insurance carriers. Directors and officers and professional liability policies often cover investigation costs but require prompt written notice.

Decide who needs separate counsel before anyone is interviewed: owners, officers, the medical director, and the compliance officer.

Keep this list with you: Download the Healthcare Fraud Defense Checklist

The Lead Attorneys Who Would Oversee Your Matter

Carolyn L. Oliver — Of Counsel, California Lead ( Former DOJ Attorney)

Carolyn Oliver spent her government career as an Assistant United States Attorney in the Major Frauds Section of the U.S. Attorney’s Office for the Southern District of California — the office that prosecutes federal health care fraud in San Diego and Imperial Counties.

As a federal prosecutor she investigated and tried health care fraud, procurement fraud, securities fraud, bank fraud, mail and wire fraud, and money laundering, handling complex multi-defendant matters involving executives and health care professionals, working with the FBI, IRS-Criminal Investigation, HHS-OIG, and DCIS. She has more than 40 years of legal experience and extensive federal jury trial experience as lead counsel. B.S., Boston University; J.D., Temple University School of Law.

What that gives you: when we assess whether a pre-indictment presentation will land with a California AUSA, that judgment comes from someone who spent years receiving them in a California federal district — who knows how a Major Frauds unit evaluates a provider case, what makes a supervisor decline, and what a case agent needs to hear.

Read her full biography →

Theodore P. Watson — Founder (Former Federal Procurement Official)

Founded Watson & Associates after more than two decades in federal procurement, including service as a Department of Defense procurement official. Admitted to practice before the Supreme Court of the United States.

Leads the firm’s work in suspension and debarment, mandatory disclosure, procurement fraud, and federal program eligibility. Full biography

How this team is structured

Most firms that defend health care fraud cases are built around the criminal case. This firm’s core practice is federal program eligibility: the payment suspension, Medicare revocation, OIG exclusion, and federal contract debarment decisions that can close an organization even when no one is charged. That work is handled by the same team handling the criminal and civil defense, from the first week, so a position taken in one proceeding does not undercut another. For organizations that also hold VA Community Care, TRICARE, IHS, or HRSA-funded work, the same team addresses the contract and grant consequences. Combined with a California lead who prosecuted fraud cases in a California U.S. Attorney’s Office, that structure is uncommon among firms handling these matters.

See all attorneys

Healthcare and Medicare Fraud Investigations: FAQs

Am I personally at risk, or only the company?

Possibly both. Federal prosecutors charge individuals, and a corporate structure does not protect someone who approved or directed the conduct under review. Company counsel represents the company, not you. If your decisions are part of what the government is examining, you likely need your own lawyer, and it is simpler to arrange before interviews begin than after.

Federal agents want to talk to me. Should I?

Not yet. You can say, politely, “I’m not going to answer questions today. My attorney will contact you.” That is not an admission. It is what nearly every federal defense lawyer advises, because an inaccurate statement to a federal agent is a separate crime under 18 U.S.C. § 1001, even when the billing itself was defensible.

We received a subpoena or a Civil Investigative Demand. Do we have to produce everything?

You must respond, but not necessarily to everything as written. Scope, date ranges, custodians, and timing are routinely negotiated with the government through counsel. A Civil Investigative Demand is a civil tool, but what you produce can be shared with criminal prosecutors, so it deserves the same care as a criminal subpoena.

Is this criminal or civil?

At the start it is often unclear, and it can be both. A grand jury subpoena, a target letter, a search warrant, or FBI involvement points toward a criminal investigation. A Civil Investigative Demand points toward a civil False Claims Act case, usually started by a whistleblower whose complaint is under seal. Identifying which track you are on is the first job of counsel.

Can a billing or coding error become a federal crime?

An error by itself is not a crime. Criminal health care fraud under 18 U.S.C. § 1347 requires a knowing and willful scheme. The risk is a pattern: a problem identified in an audit, not corrected, and repeated. Civil False Claims Act liability goes further, reaching “reckless disregard” and “deliberate ignorance” without proof of intent to defraud. What the organization did after it learned of a problem usually matters most.

We think we know who reported us. What should we do?

Nothing that affects that person’s job. Firing, demoting, or reassigning a suspected whistleblower creates a separate retaliation claim under 31 U.S.C. § 3730(h) and makes the rest of the case harder to defend.

If Medicare or Medi-Cal Payments Have Stopped

For many organizations, a payment suspension is the first sign of an investigation, and it is the part most likely to threaten payroll. Five facts matter immediately.

No charge is required. CMS can suspend Medicare payments, in whole or in part, based on a “credible allegation of fraud,” which can come from billing data analysis or audit findings. Advance notice can be skipped if CMS believes it would put funds at risk.

There is no formal appeal. The available response is a written rebuttal, and the window to submit it is short and set in the notice. CMS must consider a rebuttal within 15 days of receiving it, but the suspension stays in place while it does.

It has no fixed end date. CMS reviews a fraud-based suspension every 180 days and asks law enforcement whether the investigation is still active. Suspensions are generally expected to last no more than 18 months, but they can be extended.

Partial relief is sometimes possible. A rebuttal can support limiting the suspension to one service line, raising patient-access concerns, or requesting release of funds in cases of genuine hardship such as payroll. It should be written knowing that prosecutors may read it.

Medi-Cal can stop too. Federal rules require a state Medicaid agency to suspend payments once it finds a credible allegation of fraud, unless it finds good cause not to (42 C.F.R. § 455.23). A California provider billing both programs can lose both revenue streams in the same investigation, handled by two different agencies. The federal and state responses need to be consistent.

If your payments have already stopped, the confidential line is 1-866-601-5518.

What the Document in Your Hand Usually Means

If you received…	It usually means…
HHS-OIG subpoena	The government wants records. Often the first formal step, and it can run alongside a criminal case.
Grand jury subpoena	A federal criminal investigation is underway.
Target letter	Prosecutors believe they have substantial evidence against you. It is often the last chance to be heard before a charging decision.
Civil Investigative Demand	A civil False Claims Act investigation, usually prompted by a sealed whistleblower complaint.
Payment suspension notice	Medicare payments are stopping or have stopped, and the rebuttal window is short.
Revocation notice	CMS is ending your Medicare enrollment. Appeal deadlines run from the notice date.
UPIC or MAC audit with an extrapolated overpayment	A small sample projected across all your claims. Often the front end of a fraud referral.

 

Not sure what you have? Call 1-866-601-5518 and read us the heading. It takes a few minutes. You can also read more about Civil Investigative Demands.

When the Company’s Interests and Yours Diverge

This is the issue that matters most to owners, officers, and board members, and the one most often left until it is too late.

Why the company may decide to cooperate

On March 10, 2026, the Department of Justice adopted its first department-wide Corporate Enforcement and Voluntary Self-Disclosure Policy. It gives a company a path to a declination, meaning no criminal charges against the company, if it voluntarily discloses misconduct, fully cooperates, remediates, and has no aggravating circumstances. The company must still repay what it gained. Where a declination is not available, cooperation can still lead to a non-prosecution agreement and a reduced penalty.

Full cooperation means giving the government the facts, including facts about the individuals involved.

What that looked like in a real health care case

On July 29, 2026, DOJ announced its first health care declination under the new policy. The company, an eye care group practice, had self-disclosed and cooperated, and it was not charged. On the same day, DOJ unsealed an indictment of the company’s founder for health care fraud and kickback offenses. The company’s protection did not extend to its executive.

What this means for you

Company counsel cannot protect you and the company at the same time once the company is weighing cooperation. The earlier you have your own lawyer, the more options you keep.

Legal fees may be covered. Many bylaws, operating agreements, and indemnification agreements require the company to advance an officer’s or director’s defense costs, and D&O policies often cover individual defense. Review these documents early, before fees are incurred.

What you say in an internal interview may reach the government. Before an internal interview, company counsel should give you an Upjohn warning: they represent the company, the privilege belongs to the company, and the company can share what you say. If your own conduct is at issue, that is the moment to pause and consult your own lawyer.

Your name on the enrollment matters. Medicare enrollment records list owners, officers, and managing employees, and prosecutors use those records to decide whom to interview and whom to charge, including people who say someone else ran the business.

For boards and investors

Boards often form a special committee of independent directors to oversee an internal investigation through outside counsel, so the findings are reliable and privileged, and so the board can make the self-disclosure decision with full information. Briefings to the full board should come through counsel.

Private equity sponsors and investors are not automatically insulated. DOJ has pursued False Claims Act claims against investors that were involved in a portfolio company’s operations. Board seats, management agreements, and involvement in billing or marketing decisions are the facts that decide exposure. Loan and investment agreements may also require notice of a material investigation.

How corporate matters are resolved

Depending on the facts and the timing, a healthcare organization’s matter can end in a declination, a non-prosecution or deferred prosecution agreement, a civil False Claims Act settlement, or a plea. Civil settlements with healthcare organizations often come with a Corporate Integrity Agreement with HHS-OIG, which imposes years of compliance obligations and outside review. Each of these outcomes affects the organization’s ability to keep billing Medicare in different ways, which is why the administrative consequences have to be weighed alongside the criminal and civil ones.

Other questions executives ask

Will our D&O or professional liability insurance pay? Possibly. Many policies cover investigation or defense costs, but almost all require prompt written notice. Late notice is one of the most common ways coverage is lost.

Can we keep billing Medicare? Usually, unless payments are suspended or enrollment is revoked. Correcting a practice going forward is often appropriate, but a sudden change in billing patterns becomes evidence itself, so decide how and when with counsel.

Should we self-disclose? Only after you know what you have. The criminal policy above rewards timely disclosure, and under 31 U.S.C. § 3729(a)(2) False Claims Act damages can be reduced from triple to double for disclosure within 30 days, with full cooperation, before any investigation begins. Disclosing too early, or disclosing the wrong thing, can build the government’s case. The decision also looks different for the company than for the individuals involved.

Is a Medicare fraud lawyer different from a healthcare fraud lawyer? The terms overlap. “Medicare fraud” usually refers to Medicare claims specifically, while “healthcare fraud” also covers Medi-Cal, TRICARE, and private insurance. The same federal statutes apply. What matters more is whether the lawyer also handles the administrative side, since payment suspension and revocation are often where the organization is most at risk.

How a California Federal Case Usually Unfolds

1. A data flag. DOJ and CMS contractors compare your billing against peers in your specialty and region. An outlier pattern, such as high-level E/M coding, skin substitute volume, laboratory panels per patient, or telehealth encounter volume, can open a file without any complaint.
2. Quiet fact-gathering. Records requests, interviews of current and former employees at their homes, and contact with patients and referral sources. Leadership often learns of this secondhand.
3. Formal process and administrative action. A subpoena, CID, or target letter arrives, and a payment suspension or revocation may be imposed at any point.
4. The decision. Prosecutors decide whether to charge and whom, or DOJ decides whether to join a whistleblower’s case. The time from the first subpoena to that decision is commonly one to three years.

The most useful work happens in steps 2 and 3, while the government’s view is still forming. A quiet stretch does not mean the matter is over.

Los Angeles Healthcare and Medicare Fraud Defense

Most federal healthcare fraud cases in California are brought in the Central District of California, which covers Los Angeles, Orange, Riverside, San Bernardino, Ventura, Santa Barbara, and San Luis Obispo Counties. Cases are prosecuted by the U.S. Attorney’s Office in Los Angeles, with divisions in Santa Ana and Riverside.

The Central District’s 2026 cases show where its attention is. In the June 2026 takedown, its prosecutors charged 10 defendants, including a Whittier case involving nearly $270 million in Medi-Cal prescription drug claims, a $9 million laboratory testing case out of Norwalk, and controlled-substance prescribing charges against physicians based in Irvine. Pharmacy billing, laboratory testing, and prescribing are the areas a Los Angeles healthcare executive should watch most closely.

What that means for a Los Angeles organization: this office handles a high volume of provider cases, its prosecutors work these matters regularly, and it moves quickly on administrative tools like payment suspensions. A pre-charge presentation here has to be precise and grounded in the records, because it will be read by people who have seen many of them.

If you are looking for a Los Angeles healthcare fraud lawyer or a Medicare fraud attorney in Los Angeles or Orange County, the confidential line is 1-866-601-5518. Meetings in Los Angeles are available by appointment.

Telemedicine and Digital Health Fraud Defense

Telehealth companies, digital health platforms, and the physician networks that contract with them face a different kind of investigation from a traditional practice. The government’s theory usually is not about a single miscoded claim. It is about how the platform’s model generated orders.

The questions investigators ask. How long did the physician actually spend with each patient? Were orders for DME, genetic tests, lab panels, or prescriptions written from templates or standing orders? How were patients recruited, and how were marketers paid? Did the platform’s compensation to physicians or marketers vary with the number of orders?

The laws that apply. Paying marketers or recruiters per patient or per order can raise Anti-Kickback Statute issues for federal program business. For laboratory and addiction treatment referrals, the Eliminating Kickbacks in Recovery Act (EKRA, 18 U.S.C. § 220) reaches private insurance as well, so an arrangement designed to avoid Medicare can still be charged. Claims generated through those arrangements can create False Claims Act exposure for the platform, the ordering physicians, and the suppliers who filled the orders. Let out Californina healthcare fraud defense lawyers help.

Why Northern California is the focus. When DOJ launched the West Coast Health Care Fraud Strike Force in April 2026, it identified Silicon Valley as a center of technology-driven health care fraud. For a San Francisco, Oakland, or San Jose telemedicine company, that means prosecutors assigned full-time to these matters are reviewing the data.

Who is exposed. Founders, officers, and medical directors of the platform; the contracted physicians whose NPIs appear on the orders; and the laboratories, pharmacies, and DME suppliers that billed for them. Each usually needs separate counsel, and their interests often diverge early.

If your platform or physician network has received a subpoena, CID, or records request, the confidential line is 1-866-601-5518.

Why California Is Different Right Now

A dedicated strike force is now in Northern California. Since April 2026, the West Coast Health Care Fraud Strike Force has covered the Northern District of California, Arizona, and Nevada, with prosecutors assigned full-time to healthcare fraud.

Payment comes first. DOJ’s June 2026 National Health Care Fraud Takedown reported 1,079 providers suspended from Medicare and 1,403 with billing privileges revoked, most never criminally charged. In the same announcement, Central District of California prosecutors charged 10 defendants, including a case involving nearly $270 million in Medi-Cal prescription drug claims.

Each federal district has its own priorities. The Central District (Los Angeles, Orange County, and the Inland Empire) is the most active in the state, with recent focus on pharmacy, laboratory, and prescribing cases. The Southern District (San Diego and Imperial Counties) sees cross-border pharmacy, DME, and TRICARE-connected matters. The Northern District (San Francisco, Oakland, San Jose) is home to the new strike force. The Eastern District (Sacramento, Fresno, Bakersfield) handles rural health, home health, pharmacy, and long-term care matters. Please call our California healthcar fraud defense lawyers for more information.

Ninth Circuit law applies. In Winter v. Gardens Regional Hospital & Medical Center (9th Cir. 2020), the court held that a medical-necessity certification can be “false” even though it is a clinical opinion. In California, the defense rests on what the chart showed at the time, which makes an early, privileged review of the clinical record especially important.

Who We Represent

Healthcare CEOs, owners, CFOs, medical directors, compliance officers, and board members, along with the organizations they lead: physician groups, clinical laboratories, pharmacies, telemedicine and digital health companies, DME suppliers, wound care providers, home health agencies, behavioral health and addiction treatment programs, skilled nursing operators, Medicare Advantage and risk-bearing medical groups, billing companies and MSOs, and private equity-backed healthcare businesses.

What Happens When You Call

You do not need to prepare. No documents and no organized explanation are needed.

We work out where you stand: which agency is involved, whether the matter is criminal, civil, administrative, or more than one, and which deadlines are already running.

You leave knowing what to do this week and what to avoid. If your matter belongs with a different kind of lawyer, we will tell you.

The conversation is confidential.

1-866-601-5518 · or request a call-back at a time that suits you.

Federal Matters Only

We handle cases brought by federal agencies, including the Department of Justice, U.S. Attorney’s Offices, the FBI, HHS-OIG, DEA, and CMS, in all four California federal districts: Los Angeles, Orange County, the Inland Empire, San Diego False Claims Act attorney, San Francisco, Oakland, San Jose, Sacramento, and Fresno. We do not handle cases from the California Attorney General’s Division of Medi-Cal Fraud and Elder Abuse, county district attorneys, or the Medical Board of California. Because Medi-Cal is funded jointly by the state and federal government, the same billing can draw both federal and state attention. When it does, we handle the federal matter and coordinate with your state counsel.

Related: Federal healthcare fraud defense · Medicare fraud defense · False Claims Act whistleblower and retaliation defense

This page provides general information and is not legal advice. Contacting us does not create an attorney-client relationship. Every matter depends on its own facts, and prior results do not guarantee or predict future outcomes. Descriptions of charged cases are allegations. Sources: U.S. Department of Justice press releases and the Corporate Enforcement and Voluntary Self-Disclosure Policy (March–July 2026), 42 C.F.R. §§ 405.370–405.375 and 455.23. Figures current as of September 2026.