By: Aaron E. Kacer and Steven T. Lawrence
On September 9, 2026, in its latest Financial Trend Analysis on Health Care Fraud (FTA), the U.S. Department of the Treasury announced that the Financial Crimes Enforcement Network (FinCEN) identified approximately $17.5 billion in suspicious financial activity potentially linked to healthcare fraud.[1] The FTA was based on more than 5,700 Bank Secrecy Act (BSA) reports filed by financial institutions between March 1, 2025 and February 28, 2026.
The FTA provides detailed information regarding how financial institutions identify and report suspected healthcare fraud-related activity.[2] The FTA follows FinCEN’s March 2026 healthcare fraud advisory[3] and reflects a continued effort by Treasury, FinCEN, the Department of Justice, and other federal agencies to identify, investigate, and disrupt healthcare fraud schemes. While the FTA is directed primarily at banks and other financial institutions, it provides meaningful insight into the healthcare sectors, financial activity, and operational patterns currently receiving heightened regulatory attention.
Notable Findings
The FTA identifies several trends in suspected healthcare fraud activity:
Home Health Providers Remain a Significant Area of Focus. Home healthcare businesses were the most frequently identified provider type in the healthcare fraud-related BSA reports analyzed by FinCEN. Hospice providers, mental and behavioral health and addiction treatment providers, medical equipment suppliers, and adult day care operators also appeared frequently in the reported activity. FinCEN’s data indicates home healthcare businesses appeared frequently in the BSA reports reviewed. Healthcare organizations operating within these sectors should therefore be aware that their financial activity may receive heightened attention from financial institutions and government enforcement agencies.
Financial Institutions Are Increasingly Looking Beyond Traditional Billing Issues. One of the more notable themes throughout the FTA is FinCEN’s focus on healthcare fraud through an anti-money laundering (AML) lens rather than solely through a billing and reimbursement perspective. The report analyzes not only the receipt of healthcare payments, but also the movement of those funds after reimbursement occurs. FinCEN identified BSA reports describing suspected fraud proceeds that were used for personal expenses, luxury purchases, gambling activity, real estate related payments, transfers to apparent shell entities, and international transactions. In some cases, the reported activity involved multiple businesses, accounts, and individuals before funds ultimately reached their destination. As a result, healthcare providers may experience additional diligence from banks, lenders, payment processors, and other financial institutions seeking to better understand ownership structures, affiliated entities, reimbursement flows, and unusual transaction activity.
Schemes May Involve Multiple Payment Sources. The FTA notes that suspected fraud schemes frequently involved payments originating from multiple sources, including Medicare, Medicaid, and private insurance programs. FinCEN observed that more sophisticated schemes often involved multiple healthcare and non-healthcare entities and numerous funding streams, which could make suspicious activity more difficult to detect. FinCEN also acknowledged that legitimate healthcare providers commonly receive payments from multiple sources. Accordingly, the receipt of Medicare, Medicaid, and private-insurance payments is not itself indicative of fraud. The compliance concern generally arises when reimbursement activity, ownership relationships, expenditures, or transfers present other unexplained inconsistencies or risk indicators.
Federal Authorities Continue to Focus on Organized Fraud Networks. While many of the BSA reports described relatively straightforward activity, FinCEN also identified reported activity potentially connected to larger fraud rings, criminal networks, and entities with foreign ties. This observation is consistent with broader federal healthcare fraud enforcement initiatives, including the Department of Justice’s 2026 National Health Care Fraud Takedown, which involved federal and state coordination across numerous jurisdictions and healthcare sectors.[4] The practical implication is that regulators appear increasingly interested not only in whether claims were properly submitted, but also in understanding the movement of healthcare reimbursement funds after they are received.
Arizona Providers Should Take Notice of Broader Healthcare Trends
Arizona healthcare providers should not assume these developments are relevant only to large national healthcare systems. Although the FTA does not provide a separate analysis of Arizona activity, it cites the Arizona Attorney General’s 2026 healthcare fraud takedown case filings among the federal and state enforcement materials referenced in its discussion of sophisticated healthcare fraud schemes.[5] The Arizona enforcement initiative involved coordinated healthcare fraud prosecutions and investigations targeting alleged fraudulent billing and reimbursement activity, reflecting the broader trend of increased cooperation among federal and state enforcement agencies. For Arizona healthcare organizations, particularly those participating in Medicare, Arizona’s Medicaid program administered through the Arizona Health Care Cost Containment System (AHCCCS), and other government-funded healthcare programs, the report serves as a reminder that financial activity may be reviewed by banks, payment processors, payors, and government investigators. As a practical matter, these considerations may also be relevant for physician practices, ambulatory surgery centers, behavioral health providers, management services organizations (MSOs), and other healthcare businesses operating within private equity-backed or multi-entity structures. In those settings, clearly documented ownership, control, management relationships, and intercompany fund flows may help an organization respond effectively to questions from financial institutions, payors, or regulators.
Practical Implications for Healthcare Providers
The FTA does not create new healthcare billing requirements, fraud statutes, or compliance obligations. Rather, it provides a useful roadmap regarding the conduct and transaction patterns that financial institutions and regulators are increasingly monitoring. Healthcare providers, physician practices, health systems, management organizations, and healthcare-adjacent businesses should anticipate:
- Increased scrutiny from financial institutions regarding reimbursement flows and unusual transaction activity.
- Greater diligence concerning ownership structures, management arrangements, and related-party transactions.
- Continued attention to sectors that appeared frequently within the FTA, including home health, hospice, behavioral health, addiction treatment, medical equipment, pharmacy, laboratory, and adult day care services.
- Enhanced focus on the movement and ultimate use of healthcare reimbursement funds.
- Continued coordination between healthcare fraud enforcement efforts and financial-crimes investigations.
For many organizations, the focus may be less on implementing entirely new compliance programs and more on ensuring that existing governance, billing oversight, documentation, and financial controls can withstand increased scrutiny from banks, regulators, and law enforcement agencies.
Looking Ahead
The FTA signals that healthcare fraud remains a significant enforcement priority for Treasury and FinCEN. Combined with FinCEN’s earlier healthcare fraud advisory, Treasury’s continued encouragement of whistleblower reporting, and ongoing federal healthcare fraud enforcement efforts, healthcare organizations should expect continued attention to both billing practices and the financial movement of healthcare reimbursement funds.[6]
For healthcare providers and healthcare-adjacent businesses, the message is clear – regulators are increasingly focused not only on how healthcare dollars are earned, but also on how those dollars move through the financial system after they are received. Organizations with strong compliance programs, transparent ownership structures, well-documented management relationships, and consistent financial controls will generally be better positioned to respond to inquiries from financial institutions and regulators alike.
If you would like assistance with, or have questions regarding, how these developments may impact your organization’s compliance, governance, transactional, or risk management practices, please contact Aaron Kacer or Steve Lawrence.
[1] https://home.treasury.gov/news/press-releases/sb0625/
[2] https://www.fincen.gov/system/files/2026-09/FTA-Health-Care-Fraud.pdf
[3] https://www.fincen.gov/system/files/2026-03/FinCEN-Advisory-Health-Care-Fraud.pdf
[4] https://www.justice.gov/criminal/criminal-fraud/2026-national-health-care-fraud-takedown; https://www.justice.gov/opa/pr/national-health-care-fraud-takedown-results-455-defendants-charged-connection-over-65
[5] The Arizona enforcement initiative involved coordinated healthcare fraud prosecutions and investigations targeting alleged fraudulent billing and reimbursement activity, reflecting the broader trend of increased cooperation among federal and state enforcement agencies; https://mcusercontent.com/cc1fad182b6d6f8b1e352e206/files/abd52a0a-0e46-1f3b-ab17-d6aa1671d015/Healthcare_Fraud_Takedown_2026_AGO_compressed.pdf
[6] https://www.milliganlawless.com/healthcare/u-s-treasury-fincen-focus-on-healthcare-fraud/
