Robert DeConti

On May 27, 2026, the Department of Justice's (DOJ) Civil Division announced reforms to accelerate its review of False Claims Act whistleblower complaints alleging fraud against federally funded state-administered benefits programs. Under the new procedures, the Civil Division will prioritize these qui tam complaints by completing its initial review of the case within 60 to 120 days.

On January 27, 2026, the U.S. Department of Health and Human Services Office of Inspector General (“OIG”) issued a Special Advisory Bulletin titled “Application of the Federal Anti-Kickback Statute to Direct-to-Consumer Prescription Drug Sales by Manufacturers to Patients with Federal Health Care Program Coverage.” The Special Advisory Bulletin addresses application of the federal Anti-Kickback Statute (“AKS”) to a pharmaceutical manufacturer’s offer and sale of prescription drugs through a...

On December 18, 2025, the U.S. Department of Health and Human Services Office of Inspector General (“OIG”) published Advisory Opinion 25-11, a favorable opinion regarding discount structures proposed by a pharmaceutical manufacturer in connection with selling different vaccines. OIG analyzed four categories of discount arrangements across three different vaccines.