Treasury Proposes Whistleblower Rewards for Reporting Healthcare Fraud

April 13, 2026

Blow the Whistle, Get Paid: Treasury’s New Proposed Weapon Against Financial Crimes, Including Healthcare Fraud

Gregory Keating, Meredith Schramm-Strosser, Sherry Travers, Margaret Watson, Claire Wilson Littler + Follow Contact LinkedIn Facebook X Send Embed

At a Glance

• The U.S. Treasury Department unveiled its new plan to attack financial crimes, with a particular emphasis on those involving fraud against government healthcare plans.
• Employers in the financial sector where this bounty program is being implemented and the healthcare companies that are clients of the financial institutions should double-down on compliance and invest in training to ensure that issues are promptly spotted and remediated internally. On March 30, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) released a proposed rule to implement a new whistleblower reward program. The proposed whistleblower program would follow existing programs under the Anti-Money Laundering Act (AML) and include provisions for the payment of a bounty for reporting various financial crimes, including the Bank Secrecy Act (BSA), International Emergency Economic Powers Act (IEEPA), Trading with the Enemy Act (TWEA) and Foreign Narcotics Kingpin Designation Act (“Kingpin Act”). The proposed rule would provide a monetary reward to a whistleblower who voluntarily provided original information that leads to the successful enforcement of a covered action, and who cooperated with the Treasury and/or U.S. Department of Justice (DOJ), as needed. Where the covered action results in more than $1 million in enforcement penalties, the qualifying whistleblower could be eligible for a payout of 10 to 30 percent of the funds recovered. The new program mirrors the highly successful Dodd-Frank Whistleblower reward system for reports of tax fraud to the IRS in that the rewards will come directly from enforcement fines.

Notably, FinCEN’s proposed program permits anonymous reporting and includes protections against retaliation for the whistleblower. Unlike some other whistleblower statutes like the AML on which it is modeled, however, the proposed rule excludes several categories of people from eligibility for the bounty:

• (like AML) makes ineligible those whose job it is to report wrongdoing internally;
• those who learned of the original information because the person was an employee whose principal duties involve audit or compliance responsibilities; or
• those who learned the original information in connection with the entity’s internal processes for identifying, reporting and addressing possible violations of law by that entity, unless or until, they have made those reports internally and 120 days have passed with no corrective action taken. This proposed bounty program reflects a broader enforcement posture of the administration focused on “following the money.” Secretary of the Treasury Scott Bessent underscored the administration’s commitment to incentivized whistleblowing, stating that individuals who provide “timely, actionable information” on fraud and other forms of illicit finance will be rewarded. Bessent’s message was clear as he encouraged “individuals to come forward with credible tips to help safeguard our financial system,” which is consistent with the administration’s use of whistleblowers as a frontline enforcement tool.

This approach aligns with other whistleblower protections adopted over the past five years, including the 2019 passage of the Taxpayer First Act, which strengthened the ability of employees to blow the whistle on potential tax fraud in their workplace. By creating additional bounty programs, the government is seeking to identify misconduct that might otherwise remain hidden by making it (potentially) lucrative for employees to blow the whistle.

Treasury Department’s Advisory on Healthcare Fraud

Also on March 30, 2026, the Treasury Department issued an advisory to financial institutions (and those working for them), to be on the lookout for fraud schemes involving government healthcare programs. In this advisory, FinCEN released data revealing a significant increase in healthcare fraud schemes involving Medicare, Medicaid, and other government-funded healthcare programs, and made clear that eliminating such schemes is a top priority. Through this advisory, the government has made clear that it hopes this bounty program (if approved) can supplement existing avenues— e.g., filing a qui tam case under the False Claims Act or submitting a complaint via the DOJ Whistleblower Awards Pilot Program—to combat healthcare fraud by providing insiders with financial motivation to report fraud.

Anonymous Reporting on the Rise

In its 2026 Benchmark Report on Hotline and Investigation Management, Ethico reported that it saw a five 5% drop in the number of hotline reporters willing to self-identify, from 73% in 2024 to only 68% in 2025. A reasonable inference from this trend is that in today’s workforce, people do not feel as secure about attaching their names to hotline, compliance, or ethics reports as they once did, likely because of fear of retaliation.

Against this backdrop, bounty programs such as the one proposed by the Treasury—where anonymous complaints are not just welcomed but encouraged—can result in heighted compliance risks for employers. This is because programs such as these can incentivize employees to bypass internal reporting channels in favor of direct disclosures to the government.

For employers, this trend is critical. Anonymous reporting makes it harder for employers to address concerns early and increases the chance that allegations are reported to regulators first.

Who Does This Impact?

Although the new FinCEN program targets any financial crimes under FinCEN’s jurisdiction, the announcement of this proposed rule in conjunction with the advisory on healthcare fraud highlights the administration’s focus on this area in particular. Since the COVID-19 pandemic, financial institutions have seen a significant increase in suspicious activity reports (SARS) related to healthcare and health insurance. See FinCEN Advisory. In 2025 alone, financial institutions filed a record number of more than 3,800 initial SARs related to healthcare activities. See FinCEN Advisory, SAR Stats.

What Does This Mean for Employers?

Employers should take notice: Statistical evidence suggests that employees have significant retaliation concerns regarding reporting misconduct, that anonymous reporting is on the rise, and the government is again incentivizing individuals, including employees, to blow the whistle externally so that appropriate corrective government action can be taken. Together, these trends raise the stakes for organizations that fail to maintain robust internal compliance programs and that fail to respond appropriately to internal complaints.

Now is the moment for heightened vigilance. Employers should focus on providing robust training not only for human resources professionals, but for all supervisors, to ensure complaints are properly recognized and evaluated with the appropriate level of scrutiny. Similarly, internal protections against whistleblowers should be followed and enforced. If employees believe that complaints submitted internally will receive a thorough and unbiased investigation, and their jobs will not be at risk for making such reports, employees are more likely to report internally. By contrast, if employees fear retribution and retaliation for reporting through internal channels, they are more likely to go directly to the government, regardless of what internal company policies may mandate.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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