There’s a new DOJ–HHS False Claims Act self-disclosure pilot, and it looks like a real opportunity for searchers buying healthcare businesses. It gives eligible companies a defined pathway to disclose and resolve potential civil FCA violations, with submissions accepted through April 22, 2027. For a buyer, that creates an opportunity to identify historical exposure and work toward resolving it before closing. But taking advantage of that opportunity starts with having a diligence team that knows what to look for.
This is where clinical documentation integrity matters. Revenue can look healthy, claims can have been paid, and the underlying records can still fail to support the coding, medical necessity, or services billed. Someone needs to connect what the clinical record actually says with how the business was reimbursed. Findings from that review give the buyer something concrete to bring to the seller and transactional attorney: which claims are affected, how extensive the problem may be, and what needs to be corrected or resolved before ownership changes.
I would also pay attention to a seller who voluntarily shares that they are participating in this program. That opens a valuable diligence conversation about what was disclosed, how the exposure was calculated, what has changed operationally, and whether a resolution has actually been completed. Participation alone does not resolve the liability; the scope of the final release matters. With the right clinical documentation reviewer, healthcare attorney, and financial diligence team, a searcher can use this window to make a more informed purchase and reduce the risk of inheriting unresolved reimbursement problems. For new and experienced searchers, how do you imagine clinical documentation Integrity when you consider healthcare acquisitions?