By: Christopher Parrella, Esq., CPC, CHC, CPCO
Parrella Health Law, Boston, MA
A Health Care Provider Defense and Compliance Firm

The Department of Justice (DOJ) just made it official: Massachusetts is now a front-line battleground in the federal government’s war on health care fraud. On September 23, 2025, the DOJ announced that it has expanded its Health Care Fraud Unit’s New England Strike Force to Boston.

This move represents a dramatic increase in scrutiny and resources and it’s not just aimed at big pharma or hospital systems. If you’re a behavioral health provider, physician’s office, outpatient facility, lab, DME company, urgent care center, startup, or anything in between, your compliance game just became a priority target.

Why This Matters to You

The Strike Force model was originally launched in 2007. Now that it’s officially in Boston, the reach and speed of enforcement will intensify. In FY 2025 alone, the U.S. Attorney’s Office for the District of Massachusetts recovered over $450 million through coordinated civil and criminal health care fraud actions. DOJ prosecutors will work alongside the FBI, HHS-OIG, DEA, FDA-OCI, IRS-CI, and state-level agencies like the Massachusetts Medicaid Fraud Control Unit.

This is not a theoretical expansion. It’s a real-world increase in boots-on-the-ground enforcement capacity with access to sophisticated data analytics, federal wiretap authority, whistleblower incentives and a DOJ looking to set national precedent in a high-profile jurisdiction.

Common Targets That Could Now See Elevated Risk

1. Improper billing for bundled or unbundled services
2. Marketing arrangements that implicate the Anti-Kickback Statute (AKS) or Eliminating Kickbacks in Recovery Act (EKRA)
3. Telemedicine or virtual care documentation deficiencies
4. Improper supervision and delegation
5. Fraudulent claim submissions under Commercial insurance, MassHealth, MA Medicaid, Medicare, Medicare Advantage, TRICARE, and the VA

If you’ve been relying on outdated compliance programs, boilerplate training materials, or “we’ve always done it this way” internal policies, the time to reset is now.

What You Should Do Today

1. Conduct a Compliance Risk Audit.
   Assess your billing practices, referral sources, documentation, credentialing, and marketing arrangements. If you don’t have an independent third-party reviewer, now is the time to engage one.
2. Update Your Policies & Procedures.
   Make sure your Compliance Plan, AKS/EKRA review policies, documentation protocols, and HIPAA risk assessments are current.
3. Protect the C-Suite.
   Educate owners, investors, executives, and board members on individual liability and the DOJ’s heightened focus on corporate accountability and executive-level culpability.
4. Re-Evaluate Compensation Models.
   If your providers are incentivized to increase services or referrals, ensure those structures are compliant with federal and state fraud and abuse laws.
5. Be Prepared for Data Scrutiny.
   DOJ Strike Force teams use claims data, billing patterns, and even social media evidence. Assume they already know the answers.

Hard Call to Action: Don’t Wait for a Letter from the DOJ

The Strike Force is here, and they’re armed with subpoenas, wiretaps, data analytics, and whistleblower intel. If you’re a health care provider in Massachusetts, this is your opportunity to act proactively before you become a target.

At Parrella Health Law, we’re already working with providers across the state to:

• Conduct preemptive compliance risk assessments and chart audits
• Revise marketing, staffing, and billing policies
• Navigate whistleblower claims
• Defend against payer audits and investigations

Call us at 857.328.0382 or email Chris directly at cparrella@parrellahealthlaw.com to schedule a confidential compliance review or just to talk about any of these issues that concern you.