DOJ Turns Up the Heat: New Strike Forces in Arizona, California, and Nevada & Renewed Focus on Data Mining

On April 30, 2026, the U.S. Department of Justice (“DOJ”) announced two significant developments that materially expand the federal government’s fraud enforcement footprint and reshape the landscape for potential targets and whistleblowers. 

First, DOJ’s newly created National Fraud Enforcement Division (the “NFED”) (see our alert  here) launched the West Coast Health Care Fraud Strike Force (the “Strike Force”), a multi-district initiative covering Arizona, Nevada, and the Northern District of California.   Second, DOJ’s Civil Division announced the Fraud Oversight through Careful Use of Statistics (“FOCUS”) initiative, which formalizes DOJ’s engagement with data miners filing qui tam complaints under the False Claims Act (“FCA”).   These actions signal an aggressive, data-driven, and resource-intensive approach to combating fraud against federal programs that entities and individuals should be prepared to navigate.

NFED: West Coast Health Care Fraud Strike Force

The new Strike Force unites the NFED’s Health Care Fraud Section with participating U.S. Attorney’s Offices and operates in close partnership with HHS-OIG, the FBI, the DEA, and other federal law enforcement agencies.  It will be staffed by at least ten prosecutors from the Health Care Fraud Section, serving as a “force multiplier” for the participating U.S. Attorney’s Offices to combat what DOJ characterizes as “a health care fraud crisis that is robbing taxpayers and harming patients.”  The launch comes one week after the NFED unveiled a historic $300 million grant program for state and local prosecutors to join DOJ’s anti-fraud mission.  

Nationally, the Strike Force model has prosecuted more than 6,200 defendants who collectively billed federal health care programs and private insurers over $45 billion.  According to Assistant Attorney General for the NFED Colin McDonald, the new Strike Force responds to “data showing a significant and accelerating increase in health care fraud across all three districts,” with successful prosecution of digital health technology executives in the Northern District of California and the dismantling of Medicaid, sober home, and wound care fraud schemes in the District of Arizona. 

The Strike Force will leverage “data analytics, cross-district regional coordination, and every available legal tool to identify, investigate, and prosecute these crimes with speed and efficiency.”  The NFED sent a stark message to industry participants: “to anyone who is committing fraud in the health care industry in Arizona, Nevada, and California: this Strike Force is coming for you, whether you are committing fraud on the street, in a medical office, or in a boardroom.”  The Strike Force builds on a record-setting 2025, including the largest-ever National Health Care Fraud Takedown (see our alert here), charging more than $14.6 billion in alleged loss and returning more than $560 million to the public fisc. 

Importantly, DOJ highlighted that the Corporate Enforcement and Voluntary Self Disclosure Policy (“CEP”) (see our alert here) still applies, encouraging companies to voluntarily and timely disclose misconduct. Under the CEP, companies that voluntarily self-disclose misconduct, fully cooperate, and timely remediate may qualify for declination or significant reductions in penalties absent aggravating circumstances. 

Civil Fraud Enforcement: FOCUS Initiative for Data Miners Filing Qui Tam Complaints

The FOCUS initiative responds to a rapid increase in qui tam filings driven by data miners - companies or individuals who analyze publicly available government data for potential signals of fraud, rather than the traditional insider relators under the FCA.  DOJ received a record 980 qui tam complaints in 2024, nearly 1,300 in 2025, and over 780 already in 2026, with data miners accounting for more than 45 percent of all such filings since 2024. 

FOCUS will prioritize working with data miners who “demonstrate an insightful application of sophisticated technological capabilities to regulatory frameworks to help identify potential fraud that would otherwise go undetected.”  Deputy Assistant Attorney General Brenna E. Jenny noted that participants “should be prepared to explain what differentiates their approach, how they validate their findings, and why their methodology provides a reliable basis for identifying high-quality, actionable [FCA] matters.” 

DOJ’s guidance to relators and counsel emphasizes prioritizing high‑quality, data‑miner‑driven qui tam actions:

• Quality of leads. The best data miners offer valuable leads through high-quality, reliable, and predictive data analyses and a thorough understanding of the relevant legal obligations.
• Rule 9(b) particularity. Data miners should be mindful of the heightened pleading standard of Rule 9(b) of the Federal Rules of Civil Procedure, which requires complaints alleging fraud to state with particularity the circumstances constituting fraud.
• Scienter and falsity. Before filing, the best data miners will assess potential alternative explanations for the observed conduct and be able to articulate how the data, combined with other available evidence, suggests both scienter and falsity.
• Program and regulatory familiarity. Data miners should adequately understand program eligibility requirements and relevant regulatory frameworks and articulate them in their complaints, as well as consider partnering with others who can aid that understanding. 

DOJ has invited data miners to meet with the Civil Fraud Section to discuss their capabilities and explain why and how their data signals reliably correlate with fraud. While such meetings are not a pre‑filing requirement, DOJ has indicated it will prioritize working with data miners who demonstrate pre‑filing diligence, analytical rigor, familiarity with program rules, and legally sufficient allegations.

Key Takeaways

• Heightened West Coast health care scrutiny.  The Strike Force underscores DOJ’s determination that health care fraud has migrated to Arizona and Nevada, in addition to the established technology-driven fraud activity in Northern California.  Companies operating in the region should expect intensified, data-driven enforcement targeting Medicare, Medicaid, and TRICARE billing, as well as Silicon Valley technology-driven fraud.
• Voluntary self-disclosure leverage. DOJ’s emphasis on its new Department-wide CEP signals that DOJ may extend more favorable treatment to entities that self-report, cooperate, and timely remediate, and conversely, pursue more aggressive penalties against those that do not.  Given the Strike Force’s emphasis on speed and data analytics, the window to qualify for CEP benefits is narrowing, making proactive monitoring and prompt internal escalation more critical than ever. Companies should continue to focus on and strengthen their compliance programs and self‑reporting policies.  
• Quality-over-quantity for qui tam relators. The FOCUS initiative indicates that data-miner relators are a permanent and growing feature of the FCA landscape and that DOJ intends to improve the quality of these filings rather than discourage them.  Through FOCUS, the Civil Division will prioritize data miners with rigorous methodologies, pre-filing diligence, and Rule 9(b)-compliant pleadings, while lower-quality data-miner complaints are likely to receive less attention.
• Defense strategy for FCA targets. Defendants in data-miner-initiated FCA matters should test the factors flagged by DOJ, such as whether the complaint satisfies Rule 9(b) and plausibly alleges scienter and falsity in light of alternative explanations.
• Interagency coordination.  The NFED, Civil Division, U.S. Attorney’s Offices, HHS-OIG, FBI, DEA, state and local prosecutors funded by the new $300 million grant, and private data-miner relators now form a coordinated anti-fraud infrastructure. Companies should expect information shared with one component to be rapidly disseminated across others, increasing the likelihood of parallel scrutiny, coordinated investigative activity, and heightened enforcement risk.

Recommended Next Steps

• Reassess FCA compliance programs. Entities that receive federal funds, and particularly health care providers and contractors, should consider conducting a comprehensive review of their compliance programs to ensure they are equipped to address both traditional and data-analytics-driven FCA risk. This includes reviewing billing and coding practices, referral arrangements, and any programs tied to federal reimbursement.
• Implement internal data monitoring. Given DOJ’s increasing reliance on data analytics as an enforcement tool – both on the civil (FOCUS) and criminal (Strike Force) sides – organizations should proactively deploy their own data monitoring tools to identify and address billing anomalies, coding outliers, and other statistical patterns that could attract whistleblower or government attention. Staying ahead of the enforcement curve is now a top compliance priority.
• Train personnel on FCA risk.  All relevant personnel, including compliance officers, billing staff, and executives, should receive targeted, updated training that addresses the evolving FCA enforcement landscape, including the growing role of data analytics, the heightened 9(b) pleading standard, and DOJ’s stated enforcement priorities.
• Heightened diligence for West Coast operations. Health care providers, digital health companies, and related entities operating in Arizona, Nevada, and Northern California should be particularly alert to the increased enforcement posture in these jurisdictions.  This includes conducting targeted internal audits of Medicare, Medicaid, and TRICARE claims; strengthening controls on referral relationships and patient support programs; and ensuring robust documentation of medical necessity and fair market value determinations.
• Monitor developments closely. Both FOCUS and the Strike Force are newly launched programs that will likely evolve in the coming months. Organizations should ensure their compliance programs are well designed and resourced to monitor DOJ guidance, enforcement actions, and case law developments in order to stay ahead of emerging risks and recalibrate internal controls accordingly.

Womble Bond Dickinson (US) LLP has several hundred attorneys in offices located throughout Arizona, California, and Nevada. Womble Bond Dickinson (US) LLP’s White Collar Defense and Criminal Investigations Team navigates domestic and international clients in all manner of white collar, regulatory, corporate and congressional investigations. Our team includes a distinguished roster of veteran defense attorneys, former federal prosecutors and U.S. Attorneys who served at the highest levels of the Department of Justice and at leading United States Attorneys’ Offices. Our team includes Chambers Ranked (Band 1) lawyers and alumni of the U.S. Department of Justice, the SEC’s Enforcement Division, the U.S. Senate, House of Representatives, and in-house compliance specialists of publicly traded companies.