Treasury Targets Medicare Fraud — and Will Now Pay Whistleblowers Up to 30%
FinCEN issued two actions today: an advisory to financial institutions on Medicare/Medicaid fraud schemes, and a proposed rule creating a whistleblower award program paying 10–30% of penalties collected under the Bank Secrecy Act.
The Financial Crimes Enforcement Network issued two significant actions today: an advisory to financial institutions on fraud schemes targeting Medicare, Medicaid, and other federal and state healthcare benefit programs, and a proposed rule that would pay whistleblowers 10–30% of monetary penalties collected from qualifying enforcement actions.
The advisory, FIN-2026-A001, identifies patterns financial institutions should watch for: transactions consistent with healthcare billing fraud, money laundering through healthcare-adjacent businesses, and network activity tied to known fraud schemes against government benefit programs. It follows Treasury Secretary Bessent's trip to Minnesota earlier this year, where the federal government publicly flagged a multi-billion-dollar pandemic-era benefits fraud case as a national priority.
The Whistleblower Rule: What It Means
The proposed whistleblower award structure is meaningful. Awards of 10–30% of penalties collected under the Bank Secrecy Act and the International Emergency Economic Powers Act create a direct financial incentive for insiders like accountants, compliance officers, billing staff, contractors, to report fraud they witness inside healthcare organizations doing business with federal programs.
FinCEN launched a dedicated whistleblower tip portal in February at FinCEN.gov. Tips are accepted confidentially on fraud, money laundering, and sanctions violations. This proposed rule, if finalized, converts that tip portal from a reporting mechanism into a compensated incentive program.
The Healthcare Fraud Landscape
Healthcare benefit fraud against federal programs is one of the highest-volume categories in federal criminal enforcement. The Minnesota pandemic fraud case, which federal prosecutors estimate could exceed $9 billion, is the most prominent current example, but it is not an outlier in structure. Fraudulent billing, phantom patient schemes, kickback arrangements, and identity theft-enabled claims are all documented patterns. FinCEN's advisory is a signal to financial institutions to treat transactions consistent with these patterns as suspicious activity warranting SAR filings.
If You Have Information
Victims of cyber-enabled healthcare fraud schemes should file a complaint with the FBI's Internet Crime Complaint Center at ic3.gov or contact their nearest FBI field office. Individuals with information about fraud involving HHS programs should report to HHS-OIG directly. The FinCEN tip portal is available for financial crime reporting.
Paying whistleblowers is a proven enforcement multiplier. Whether this proposed rule survives the comment period intact is the question.
- 01Treasury Targets Fraud Schemes Exploiting Government Health Care Benefits— U.S. Department of the Treasury
- 02FinCEN Issues Advisory on Health Care Fraud Schemes Targeting Medicare, Medicaid, and Other Federal and State Health Care Benefit Programs— FinCEN
- 03FinCEN Proposes Rule to Pay Whistleblowers— FinCEN
- 04Federal Register :: Whistleblower Incentives and Protections— Federal Register
