The annual National Health Care Fraud Takedown, announced by the Department of Justice (DOJ) on June 23, 2026 (the “2026 Takedown”), reinforces several enforcement priorities—opioid diversion, wound care fraud, and kickback schemes—while signaling a sharper focus on Medicaid fraud and the government’s expanding use of advanced data analytics.

On June 3, 2026, CMS issued an Interim Final Rule titled “Medicaid Program; Community Engagement Requirement for Certain Individuals,” (Interim Final Rule) establishing federal parameters for state implementation of Medicaid community engagement (i.e., work reporting) requirements for certain populations. The Interim Final Rule implements provisions of the President’s One Big Beautiful Bill Act signed into law in July 2025 (OBBA). Many stakeholders were surprised by the Interim Final Rule, especially with respect to its treatment of the “medically frail exemption,” which CMS narrowed significantly compared to OBBA statutory text. CMS’s interpretation of this exemption and its subsequent implementation will likely have significant impacts on states, hospitals, Medicaid managed care organizations (MCOs), and other providers. 

The Trump administration has decertified and defunded Hawaii’s Medicaid Fraud Control Unit (MFCU), withholding $3 million in federal funds. As detailed in a previous post, in May, the Office of Inspector General for the Department of Health and Human Services (HHS-OIG) informed every state of its intent to review the activities of its MFCU. On June 4, 2026, HHS-OIG escalated further and followed through with its threats by formally denying recertification of Hawaii’s MFCU based on its failure to pursue Medicaid fraud effectively. 

The Trump administration has stepped up its Medicaid fraud enforcement efforts, as demonstrated through a variety of agency actions taken over the past few months. The focus on Medicaid fraud undoubtedly will result in increased scrutiny of Medicaid providers and Medicaid managed care organizations (MCOs) by state and federal enforcement authorities.  

On May 13, 2026, the Centers for Medicare & Medicaid Services (CMS) issued a press release and a Federal Register notice announcing a nationwide moratorium on the enrollment of new home health agencies (HHAs) and hospices, effective immediately. Under the moratorium, new providers are barred from enrolling in Medicare as HHAs or hospices for a six-month period.

Last week, the Centers for Medicare & Medicaid Services (CMS) released its proposed Contract Year 2027 Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, and Medicare Cost Plan Program (Proposed 2027 Rules).

As is common for the annual proposed rules, the Proposed 2027 Rules cover a broad range of topics. In the last few years, the agency has lost multiple legal cases challenging the validity of its rules and/or how it implements its rules – it has lost cases relating to Star Ratings, its updated marketing and communications rules that were adopted for 2025, and most recently, the risk adjustment extrapolation rule. The Proposed 2027 Rules broadly touch on all of these regulatory areas. In its very brief summary of the Proposed 2027 Rules, CMS also highlights changes to Part D drug coverage, the enrollment process, and special needs plans. The Proposed 2027 Rules also include multiple Requests for Information (RFI). Below are some initial takeaways.

HRSA launches 340B rebate pilot tied to Medicare drug negotiations, signaling major program shifts amid legal rulings and stakeholder concerns.

States and manufacturers clash over 340B contract pharmacy laws as litigation mounts and courts weigh in on the future of pharmacy access protections.

CMS proposes OPPS payment cuts and a drug cost survey, signaling major 340B reimbursement shifts and renewed scrutiny of hospital payment rates.

Senate HELP Committee releases 340B report urging transparency, oversight, and reforms amid uncertainty over future federal legislative action.