18 U.S.C. § 1347 Healthcare Fraud: Elements, Defenses, and Federal Enforcement
Why 18 U.S.C. § 1347 Anchors Every Federal Healthcare Fraud Investigation
Healthcare fraud under 18 U.S.C. § 1347 is the lead charge in most federal healthcare prosecutions. When the Department of Justice investigates a physician, a clinic owner, or a healthcare executive, Section 1347 is almost always the statute driving the grand jury subpoenas, the search warrants, and the charging decision. Each count carries up to 10 years in federal prison. The exposure climbs to 20 years if the scheme results in serious bodily injury, and to life imprisonment if it results in death.
Enforcement is at a historic high. The 2025 National Health Care Fraud Takedown charged 324 defendants across 50 federal districts in connection with $14.6 billion in alleged intended loss. In April 2026, DOJ launched a West Coast Health Care Fraud Strike Force to expand that footprint. The DOJ Fraud Section's Health Care Fraud Unit now pairs CMS claims data with AI-driven analytics to identify billing outliers and open investigations faster than ever. Nearly all of those investigations are built around Section 1347.
The statute's reach explains its prominence. Its limits define the defense. Section 1347 is a specific intent crime. It punishes deliberate deception, not billing mistakes, documentation lapses, or disagreements over Medicare's rules. Two doctrines define that boundary. First, a violation of a Medicare rule or regulation is not, by itself, a violation of Section 1347. Second, good faith is a complete defense. Both doctrines come straight from the case law, and both shape how these investigations are defended.
The Elements of Healthcare Fraud Under Section 1347
To convict a defendant of healthcare fraud, the government must prove each of the following elements beyond a reasonable doubt. Federal courts of appeals have applied this framework consistently, including in United States v. Ganji, 880 F.3d 760 (5th Cir. 2018), United States v. Scott, 61 F.4th 855 (2023), United States v. Beaufils, 160 F.4th 1147 (2025), and United States v. Otuonye, 171 F.4th 1192 (2026).
Each element is a battleground. The government's proof on intent, falsity, and materiality decides most contested healthcare fraud trials.
Intent: Knowingly and Willfully
Section 1347 requires the government to prove that the defendant acted both knowingly and willfully. Acting knowingly means the defendant was aware of the facts that make up the offense. Acting willfully means the defendant knew the conduct was unlawful and intended to engage in it anyway. The statute adds one clarification at Section 1347(b): the defendant need not have actual knowledge of the statute itself or a specific intent to violate that particular section.
Specific intent to defraud requires more than a false statement. It requires an intent to deceive or cheat someone, such as a health care benefit program, in order to obtain something of value. Otuonye, 171 F.4th 1192. That is the heart of the crime. A claim that is wrong is not enough. A claim that is dishonest is.
Falsity
False or fraudulent pretenses, representations, or promises are statements that were untrue when made and were either known by the defendant to be untrue or made with reckless indifference to their truth or falsity. Otuonye, 171 F.4th 1192. The government must prove falsity at the moment the representation was made, not in hindsight.
Materiality
Not every false statement supports a conviction. The misrepresentation must be material. A fact is material if it has a natural tendency to influence, or is capable of influencing, the decision of the decision-making body to which it was addressed. The Supreme Court established that materiality is an element of the federal fraud statutes in Neder v. United States, 527 U.S. 1 (1999), and the Fourth Circuit applied that rule to Section 1347 in United States v. Palin, 874 F.3d 418 (4th Cir. 2017). In practice, materiality asks whether the alleged misstatement actually mattered to the payor's decision to pay. Where the insurer would have paid the claim anyway, the government's case has a problem.
How Section 1347 Is Charged with Section 1035 and the Anti-Kickback Statute
Section 1347 rarely stands alone in an indictment. Federal prosecutors layer companion charges around it, and two appear more than any others: false statements relating to health care matters under 18 U.S.C. § 1035 and the Anti-Kickback Statute under 42 U.S.C. § 1320a-7b. Each serves a distinct function in the government's case. Each has its own elements, its own penalties, and its own defenses.
Section 1035: False Statements in Health Care Matters
Section 1035 makes it a crime to knowingly and willfully falsify or conceal a material fact, or to make a materially false statement, in connection with the delivery of or payment for health care benefits, items, or services. Each count carries up to five years in prison. Like Section 1347, the statute requires materiality and a knowing and willful state of mind.
The difference is structural. Section 1347 requires a scheme. Section 1035 does not. A single claim form, a single certification of medical necessity, or a single statement to an HHS-OIG agent can support a Section 1035 count. Prosecutors exploit that difference. The Section 1347 counts frame the overall scheme for the jury. The Section 1035 counts isolate specific documents and statements within it, giving the jury smaller, more concrete charges to convict on even if it doubts the scheme as a whole. Section 1035 also reaches statements made during the investigation itself, so an interview with federal agents can generate new felony exposure independent of any billing conduct. The firm's analysis of false statement charges under Section 1035 covers the elements and defenses in detail.
The Anti-Kickback Statute
The Anti-Kickback Statute prohibits offering, paying, soliciting, or receiving remuneration to induce referrals for items or services reimbursable by a federal healthcare program. Each count carries up to 10 years. When prosecutors charge the AKS alongside Section 1347, the kickback supplies the fraud theory. The government alleges that claims procured through kickbacks are false or fraudulent because they conceal the tainted referral relationship and misrepresent that services were ordered based on medical judgment rather than payments. Congress reinforced that linkage in 42 U.S.C. § 1320a-7b(g), which provides that a claim including items or services resulting from an AKS violation is a false or fraudulent claim for purposes of the False Claims Act.
The pairing changes the trial. AKS counts require proof of willfulness and an inducement purpose, and they open the door to safe harbor and fair-market-value defenses that have no analogue under Section 1347. They also widen the evidence, bringing financial arrangements, marketing contracts, and referral data into a case that might otherwise turn on billing records alone. The firm's analysis of the Anti-Kickback Statute's elements, safe harbors, and defenses addresses those issues directly.
Conspiracy completes the package. Prosecutors typically add a count under 18 U.S.C. § 1349, which punishes conspiracy to commit healthcare fraud with the same penalties as the completed offense, and a count under 18 U.S.C. § 371 for AKS conspiracies. The stacked counts raise the guidelines exposure and the plea pressure. They also multiply the elements the government must prove, and the intent defenses discussed below, including good faith, cut across all of them.
A Violation of Medicare Rules Is Not a Violation of Section 1347
This is the doctrine that federal prosecutors least like to discuss. Medicare's rules fill thousands of pages of statutes, regulations, manuals, and local coverage determinations. Providers violate them constantly, usually without knowing it. CMS's own improper payment data confirms how common billing errors are. None of that is a federal crime. Courts have held that the government must prove fraudulent conduct, not merely a departure from a Medicare rule or regulation.
In United States v. Renick, 273 F.3d 1009 (11th Cir. 2001), the jury was explicitly instructed that violations of federal health program regulations do not amount to criminal conduct under Section 1347. The court told the jury that the defendants were not charged with violating regulations and that any such violation "is not a criminal offense for purposes of this case." Where the regulations were ambiguous, the jury was further instructed that the government had to prove beyond a reasonable doubt that the defendants knew their actions violated the applicable Medicare rules.
"A violation of a regulation is not in itself a criminal offense."
Jury instruction approved in United States v. Abdallah, 629 F. Supp. 2d 699 (S.D. Tex. 2009)The court in Abdallah went further. It instructed the jury that evidence of regulatory violations could be considered only for the limited purpose of assessing the defendant's intent or state of mind. The regulatory violation itself could not satisfy the elements of healthcare fraud. That instruction was upheld as an accurate statement of the law.
Prosecutors often build Section 1347 cases on a foundation of noncompliance: claims that lacked required documentation, services that arguably failed a coverage rule, or certifications that an auditor would reject. Standing alone, that evidence proves a billing dispute. It does not prove fraud. The defense holds the government to the actual elements, which require a knowing and willful scheme to deceive, not a paper trail of regulatory imperfection.
Good Faith Is a Complete Defense to Healthcare Fraud
Good faith defeats a Section 1347 charge entirely. The logic is simple. The crime requires an intent to defraud. A defendant who honestly believed the claims were proper, or who made a mistake in judgment, did not intend to defraud anyone. Good faith and fraudulent intent cannot coexist. The Sixth Circuit put it directly in United States v. Hills, 27 F.4th 1155 (6th Cir. 2022): good faith is a defense because it "is, simply, inconsistent with an intent to defraud."
The Third Circuit's instruction in United States v. Hoffecker, 530 F.3d 137 (3d Cir. 2008), captures the full doctrine. Good faith is a complete defense because it negates the intent to defraud and the willfulness that the charges require. The defendant bears no burden to prove good faith. The government must prove specific intent to defraud beyond a reasonable doubt. And a person who expresses an honestly held opinion or an honestly formed belief is not chargeable with fraudulent intent, even if the opinion is erroneous or the belief mistaken. Evidence showing only a mistake in judgment, an error in management, or carelessness does not establish fraudulent intent. The Fourth Circuit approved nearly identical instructions in United States v. Bakker, 925 F.2d 728 (4th Cir. 1991).
Two limits apply. First, good faith does not protect a defendant who knowingly made false representations with the intent to deceive. Bakker, 925 F.2d 728. Second, the instruction must fit the evidence. In Hills, the court declined to give a requested honest-mistake instruction because the trial record did not support that theory, and it held that any error was harmless because the jury's finding of intent to defraud necessarily negated good faith. Courts reached a similar result in United States v. Awad, 551 F.3d 930 (9th Cir. 2009), where a flawed willfulness instruction was deemed harmless for the same reason.
The lesson for the defense is to build the good faith record early. Contemporaneous documentation, reliance on billing consultants or counsel, consistent clinical judgment, and candid internal communications all support the defense at trial. They also support it before trial, when defense counsel presents the case to prosecutors deciding whether to charge.
Why Trial Practice Decides Healthcare Fraud Cases
Every doctrine in this article gets tested in a courtroom, through cross-examination and proof. Section 1347 requires the government to prove intent beyond a reasonable doubt, and intent almost never comes from documents alone. It comes from witnesses. The defense that knows how to take those witnesses apart, and how to build an affirmative good faith case for the jury, controls the outcome.
Cross-Examining the Government's Witnesses
The government's intent case typically rests on four categories of witnesses, and each is vulnerable on cross-examination.
Cooperating witnesses carry the heaviest load. Former employees, billers, marketers, and co-defendants testify under plea agreements and immunity deals, often with sentence reductions riding on the government's satisfaction with their testimony. That arrangement is fertile ground for cross. Under Giglio v. United States, 405 U.S. 150 (1972), the government must disclose those deals, and a jury that understands what a cooperator stands to gain weighs the testimony differently. Cooperators also rarely have direct knowledge of the defendant's state of mind. Cross-examination pins them to what they actually saw and said at the time, which is usually far less than the direct examination implied.
Data witnesses present the government's billing analytics: outlier comparisons, coding distributions, peer benchmarks. The methodology is open to attack. Who was in the comparison population. Whether patient acuity was controlled for. Whether the analyst knows anything about the clinical practice behind the codes. An outlier chart proves a provider billed differently. It does not prove the provider intended to defraud anyone, and a well-built cross makes the analyst concede exactly that.
Payor witnesses from CMS contractors and insurers testify that the claims would not have been paid if the truth were known. That testimony goes to materiality, and it often collapses under questioning about what the payor actually reviewed, what the coverage rules actually required, and what the payor paid in comparable circumstances. Where the payor would have paid the claim anyway, the materiality element fails.
Ambiguity in the rules is the sharpest tool against the government's experts. Medicare's requirements come from layered sources: statutes, regulations, manual provisions, and local coverage determinations, and those sources rarely speak with one voice. Some conduct is expressly required. Some is left to clinical or billing discretion. Much is not addressed at all. Cross-examination walks the expert through those layers and demands precision. Where, exactly, does the rule say what the expert claims it says. Is the cited provision a binding regulation or sub-regulatory guidance. Does it mandate the documentation the expert faulted, or describe one acceptable approach among several. An expert who concedes that the rule is silent, or that reasonable providers read it differently, has conceded the ambiguity. That concession feeds the intent defense directly. As Renick instructs, where the regulations are ambiguous, the government must prove the defendant knew the conduct violated them. A defendant cannot willfully violate a rule that no one could read with confidence.
Marshaling the Evidence of Good Faith
Cross-examination tears down the government's intent case. The good faith defense requires building one. Courts require an evidentiary foundation before instructing the jury on good faith, as United States v. Hills, 27 F.4th 1155 (6th Cir. 2022), makes clear, so the defense must put real evidence behind the theory: contemporaneous clinical documentation showing individualized judgment, compliance program records, written guidance from billing consultants or counsel, candid internal communications that show no consciousness of wrongdoing, and consistent treatment of patients whose claims were never challenged. Presented together, that record gives the jury a concrete basis to find that the defendant honestly believed the claims were proper, which negates the intent to defraud as a matter of law.
Trial readiness shapes the case before it ever reaches a jury. Prosecutors calibrate charging decisions and plea offers based on whether the defense will fold or fight. Scott Armstrong and Drew Bradylyons tried and supervised these cases at DOJ's Fraud Section, where they watched defense counsel across the courtroom for years. A defense team that has tried 25 federal jury cases, 17 of them healthcare fraud trials, changes the government's calculation at every stage, from the grand jury through the verdict.
What These Doctrines Mean in a Federal Investigation
Section 1347 investigations rarely begin with proof of intent. They begin with data. An algorithm flags a provider as a billing outlier. An auditor identifies claims that fail a coverage rule. A whistleblower alleges noncompliance. Each of those starting points describes a regulatory problem, not a crime. The government's task is to convert noncompliance into proof of a knowing and willful scheme to defraud. The defense's task is to stop that conversion.
That is where the two doctrines above do their work. The rule that regulatory violations are not crimes confines the government to its actual burden. The good faith defense gives the jury a legal framework for acquittal when the evidence shows honest belief, ambiguous rules, or ordinary error. Together with the materiality requirement, these doctrines supply the architecture of a healthcare fraud defense from the first subpoena through the verdict.
As a former Assistant Chief in DOJ's Fraud Section, Scott Armstrong tried nine federal healthcare fraud jury trials and served as lead counsel in cases totaling over $600 million in alleged false claims. Drew Bradylyons served as Assistant Chief of the Fraud Section's Healthcare Fraud Unit, supervised the Miami Strike Force, and oversaw investigations involving more than $1 billion in fraudulent claims. They built Section 1347 cases for the government. They know where the elements are vulnerable, and they now apply that knowledge to healthcare fraud defense nationwide.
Frequently Asked Questions: 18 U.S.C. § 1347 and Federal Healthcare Fraud Charges
What are the elements of healthcare fraud under 18 U.S.C. § 1347?
To convict a defendant of federal healthcare fraud, the government must prove four elements beyond a reasonable doubt. First, the defendant knowingly and willfully executed or attempted to execute a scheme or artifice to defraud a health care benefit program, or to obtain money or property of such a program through false or fraudulent pretenses, representations, or promises. Second, the scheme was connected to the delivery of or payment for health care benefits, items, or services. Third, the health care benefit program affected interstate commerce. Fourth, the false representations concerned a material fact.
Materiality is an implicit element drawn from the common-law definition of fraud, as the Supreme Court held in Neder v. United States, 527 U.S. 1 (1999), and as the Fourth Circuit applied to Section 1347 in United States v. Palin, 874 F.3d 418 (4th Cir. 2017). Courts of appeals apply this same framework in United States v. Ganji, United States v. Scott, United States v. Beaufils, and United States v. Otuonye. Each element is independently contestable. The firm's founders tried these elements to federal juries as DOJ Fraud Section prosecutors, and the failure of any one element defeats the charge.
How does the government prove intent to commit healthcare fraud?
Section 1347 requires proof that the defendant acted knowingly and willfully with a specific intent to defraud. Acting knowingly means the defendant was aware of the facts that make up the offense and did not act through ignorance, mistake, or accident. Acting willfully means the defendant knew the conduct was unlawful and intended to engage in it. Section 1347(b) provides that the defendant need not know the statute itself exists, but the government must still prove an intent to deceive or cheat a health care benefit program to obtain something of value.
Because direct evidence of intent is rare, federal prosecutors prove it circumstantially: billing patterns that diverge from peers, internal emails and texts, testimony from cooperating employees and billers, and evidence of concealment. Having built Section 1347 cases inside DOJ's Fraud Section, the firm's attorneys know how that circumstantial record is assembled and where it breaks down. The defense answers with contemporaneous clinical documentation, reliance on billing guidance and consultants, ambiguous coverage rules, and evidence of honest belief, each of which undercuts the inference of deliberate deception.
Is a Medicare billing error or regulatory violation a federal crime?
No. A violation of a Medicare rule or regulation does not, by itself, constitute healthcare fraud under 18 U.S.C. § 1347. In United States v. Renick, 273 F.3d 1009 (11th Cir. 2001), the jury was instructed that violations of federal health program regulations are not criminal offenses, and that where the regulations were ambiguous, the government had to prove the defendants knew their actions violated the applicable rules. In United States v. Abdallah, 629 F. Supp. 2d 699 (S.D. Tex. 2009), the court approved an instruction that a regulatory violation "is not in itself a criminal offense" and limited that evidence to the question of intent.
The distinction separates a billing dispute, which belongs in an audit or administrative appeal, from a federal felony. Regulatory noncompliance can be evidence bearing on a defendant's state of mind, but it cannot substitute for proof of a knowing and willful scheme to defraud. Holding the government to that line is a core part of defending these cases, in audits, grand jury investigations, and trials.
Is good faith a defense to federal healthcare fraud charges?
Yes. Good faith is a complete defense to a Section 1347 charge because it negates the intent to defraud and the willfulness the statute requires. As the Sixth Circuit explained in United States v. Hills, 27 F.4th 1155 (6th Cir. 2022), good faith is simply inconsistent with an intent to defraud. The defendant bears no burden to prove good faith. The government must prove specific intent to defraud beyond a reasonable doubt.
The jury instructions approved in United States v. Hoffecker, 530 F.3d 137 (3d Cir. 2008), and United States v. Bakker, 925 F.2d 728 (4th Cir. 1991), define the doctrine's scope. A person who expresses an honestly held opinion or belief is not chargeable with fraudulent intent, even if the opinion is wrong. A mistake in judgment, an error in management, or carelessness does not establish fraud. Two limits apply: the defense does not protect knowingly false representations made to deceive, and courts require an evidentiary foundation before instructing the jury. Contemporaneous compliance records, candid communications, and documented reliance on professional guidance build that foundation, which is why experienced defense counsel develops the good faith record from the first day of an investigation.
What triggers a federal healthcare fraud investigation under Section 1347?
Most Section 1347 investigations begin with data, not a complaint. CMS program integrity contractors and the DOJ Fraud Section's Health Care Fraud Unit mine Medicare and Medicaid claims data to flag billing outliers: providers whose volume, coding mix, or patient population diverges from peers. Other common triggers include UPIC audits, HHS-OIG subpoenas, qui tam whistleblower complaints filed under seal, referrals from private insurers, and cooperating witnesses in related cases. The 2025 National Takedown and the new Health Care Fraud Data Fusion Center reflect how central analytics have become to case generation.
Early indicators of federal interest include a civil investigative demand, a grand jury subpoena, an unannounced agent interview, a payment suspension, or a target letter. The firm's founders generated and supervised these investigations at DOJ, including the Fraud Section's first use of data analytics to convict a physician, and they now defend providers at every stage of that process. A billing anomaly is a lead, not proof of fraud, and the methodology behind an outlier report is itself open to challenge.
Where does Armstrong & Bradylyons PLLC defend federal healthcare fraud cases?
Based in Washington, D.C., Armstrong & Bradylyons PLLC defends Section 1347 investigations and prosecutions in federal courts nationwide, the same way Scott Armstrong and Drew Bradylyons practiced at DOJ's Fraud Section, which charges cases in every federal district. The firm's healthcare fraud defense practice is built around the Strike Force cities where DOJ concentrates these prosecutions: the Southern District of Florida, the Eastern District of Michigan, the Southern District of Texas, the Central District of California, the District of Massachusetts, and the Northern District of Illinois, along with the West Coast Strike Force launched in 2026 covering San Francisco, Las Vegas, and Phoenix. Healthcare fraud prosecutions also originate from U.S. Attorney's Offices beyond the Strike Force footprint.
That national reach rests on a national trial record. The firm's attorneys have participated in 25 federal jury trials, 17 of them healthcare fraud cases involving over $2.8 billion in alleged false claims, in courts around the country. Drew Bradylyons supervised the Healthcare Fraud Unit's busiest docket in the Southern District of Florida, and Scott Armstrong tried cases in Strike Force districts from Texas to the District of Columbia. The firm represents clients in every jurisdiction where DOJ brings healthcare fraud and Anti-Kickback Statute cases.
What are the penalties for healthcare fraud under 18 U.S.C. § 1347?
Each count of healthcare fraud carries up to 10 years of imprisonment and criminal fines under 18 U.S.C. § 3571. The maximum rises to 20 years if the scheme results in serious bodily injury and to life imprisonment if it results in death. Sentences are driven by the federal sentencing guidelines, where the alleged loss amount is usually the dominant factor, alongside restitution and forfeiture.
The collateral consequences often exceed the sentence. A program-related conviction triggers mandatory exclusion from Medicare, Medicaid, and all federal healthcare programs under 42 U.S.C. § 1320a-7(a), administered through the HHS-OIG exclusions program, and state licensing boards typically open parallel proceedings. For most physicians and healthcare executives, exclusion ends the career regardless of the prison term. That is one reason Section 1347 cases go to trial more often than other federal fraud charges, and why a defense built by attorneys who have actually tried these cases carries weight in charging and plea negotiations.
What does materiality mean in a Section 1347 healthcare fraud case?
Materiality requires the government to prove that the false representation concerned a fact significant enough to influence the decision of the body to which it was addressed, typically the insurer or government program deciding whether to pay the claim. The standard comes from Neder v. United States, 527 U.S. 1 (1999), where the Supreme Court held that the federal fraud statutes incorporate the common-law materiality requirement, and from United States v. Palin, 874 F.3d 418 (4th Cir. 2017), which applied that holding to Section 1347.
Materiality converts the question from "was the statement false" to "did the falsehood matter to payment." Where the payor would have paid the claim regardless of the alleged misstatement, or where the disputed entry had no bearing on coverage criteria, the element fails. In data-driven prosecutions built on coding disputes and documentation gaps, materiality is often the government's weakest element and a focus of pretrial motions, cross-examination of payor witnesses, and jury argument.
Why is Section 1347 the lead charge in federal healthcare fraud prosecutions?
Section 1347 reaches the conduct at the center of nearly every healthcare enforcement theory: the submission of false claims to a health care benefit program. It covers both government programs and private insurers, requires no proof of an actual loss, and supports companion charges including conspiracy under 18 U.S.C. § 1349, false statements under 18 U.S.C. § 1035, wire fraud, the Anti-Kickback Statute, and money laundering. It is the workhorse statute of the DOJ Fraud Section's Health Care Fraud Unit and the national Strike Force model.
Current enforcement priorities amplify its role. The 2025 National Takedown charged 324 defendants in connection with $14.6 billion in alleged intended loss, and DOJ's analytics now generate Section 1347 investigations directly from CMS claims data. Because the statute carries the longest baseline exposure among the core healthcare charges and frames the entire scheme for the jury, it is typically the count around which both the indictment and the defense are organized.
Why do indictments pair Section 1347 with 18 U.S.C. § 1035 and the Anti-Kickback Statute?
The three statutes cover different conduct, and the combination strengthens the government's hand. Section 1347 requires proof of a scheme to defraud. 18 U.S.C. § 1035 criminalizes individual materially false statements made in connection with health care benefits, items, or services, with a five-year maximum per count. It requires no scheme, so prosecutors use it to charge specific claim forms, certifications, and statements to investigators, and it gives the jury a fallback conviction if the scheme allegation fails. The Anti-Kickback Statute, 42 U.S.C. § 1320a-7b, carries a 10-year maximum per count and supplies a fraud theory of its own: claims procured through kickbacks are alleged to be false because they conceal the tainted referral relationship.
The pairing also reshapes defense strategy. Materiality applies to both Section 1347 and Section 1035. The AKS adds safe harbor and fair-market-value defenses unavailable under the fraud statutes. Good faith, which negates fraudulent intent and willfulness, cuts across all three. The firm's analyses of Section 1035 false statement charges and Anti-Kickback Statute defense address each charge in depth.
What experience does Armstrong & Bradylyons PLLC bring to a Section 1347 healthcare fraud defense?
Armstrong & Bradylyons PLLC was founded by former senior prosecutors from DOJ's Fraud Section, the unit that brings most Section 1347 prosecutions. Scott Armstrong served as an Assistant Chief and tried sixteen complex federal cases, including nine healthcare fraud jury trials, serving as lead counsel in cases totaling over $600 million in alleged false claims and in the Fraud Section's first use of data analytics to convict a physician. Drew Bradylyons served as Assistant Chief of the Healthcare Fraud Unit, supervised the Miami Strike Force's docket, led the Financial Crimes and Public Corruption Unit at the U.S. Attorney's Office for the Eastern District of Virginia, and oversaw investigations involving more than $1 billion in fraudulent claims to Medicare, Medicaid, and TRICARE.
Together the firm's attorneys have participated in 25 federal jury trials, 17 of them healthcare fraud cases involving over $2.8 billion in alleged false claims. Based in Washington, D.C., the firm's healthcare fraud and Anti-Kickback Statute defense practice represents physicians, clinic owners, and healthcare executives in Section 1347 investigations and prosecutions in federal courts nationwide, in every district where the Strike Force and U.S. Attorney's Offices bring these cases.
Facing a Federal Healthcare Fraud Investigation?
Armstrong & Bradylyons PLLC defends physicians, clinic owners, and healthcare executives in federal investigations and prosecutions under 18 U.S.C. § 1347 nationwide. As former Assistant Chiefs in DOJ's Fraud Section, Scott Armstrong and Drew Bradylyons built and tried these cases for the government. The firm provides a trial-ready defense in complex healthcare fraud matters.
