Healthcare matters · National preparation support
Civil and Criminal Healthcare Fraud Matters: Separate the Records
Distinguish payer demands, civil proceedings and criminal allegations when organizing a healthcare case. Prepare separate timelines and questions for counsel.
By Joseph De Gregorio · Federal Sentencing Strategist
Founder and President, Sentencing Advocacy Group · November 6, 2026
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Identify each proceeding independently
Healthcare matters can involve civil, criminal and administrative issues. HHS OIG’s physician education materials describe distinct fraud-and-abuse authorities. The presence of one type of notice does not tell you that every other process has ended or begun. List the issuing body, named recipient, document date, requested action and current status for each proceeding.
Do not treat every financial demand as the same number
A payer recoupment demand, a civil settlement amount, a proposed sentencing loss and a restitution request may use different assumptions. Record what each amount purports to measure. Keep the underlying calculation, period and source together. Ask counsel to determine relationships between the proceedings rather than assuming a payment resolves every form of exposure.
Track parallel deadlines
Build one calendar with a separate lane for each proceeding. Include counsel’s internal review dates and the person responsible for obtaining records. Distinguish a proposal, a filed document and a final order. Avoid describing a negotiated term as final before the legal team confirms its status.
Preserve consistency without forcing identical accounts
The same underlying event may appear in several files. Maintain one source chronology and note where descriptions differ. Do not edit records merely to make the narratives match. Counsel should review discrepancies and decisions about statements or submissions. Your task is to identify the difference and the materials needed to understand it.
Connect restrictions to practical planning
Employment, clinical duties, business income and family obligations may change during a matter. Record confirmed restrictions separately from feared possibilities. Build a practical plan around what is authorized now and list contingencies for unresolved decisions. Professional licensing and program-participation questions belong with appropriate counsel.
Continue your preparation
- Overpayment and Criminal Loss
- Healthcare Fraud: Professional Future Planning
- Healthcare Fraud Investigation
Does repayment mean the criminal matter is over?
Do not assume that. Ask counsel what the payment addresses and whether any other proceedings or obligations remain. Keep the actual agreement and payment records.
Sources and professional scope
Official context: HHS OIG’s overview of healthcare fraud and abuse authorities. Its overview is educational and includes historical penalty figures; consult current authorities with counsel. U.S. Sentencing Commission guidelines resources support counsel’s sentencing review. Sources checked November 6, 2026.
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