On October 22, 2026, the Justice Department's Civil Division and HHS launched the Healthcare False Claims Act Self-Disclosure Pilot Program (FCA SDPP). It offers healthcare companies a coordinated civil release for disclosing potential FCA violations previously unknown to the government, at a repayment of 1.25 to 1.6 times a base amount instead of the FCA's treble damages. Andrew Hillman walks through what the protocol says, why the math matters and a nine-point operator checklist for the six-month window, which closes at 11:59 PM on April 22, 2027. Hosted by Andrew Jonathan Hillman, Dallas, Texas. Read the Letter: https://thehillmanletter.substack.com/p/fca-self-disclosure-pilot Main site: https://andrew-hillman.com/ Takeaways: - Repayment is 1.25 to 1.6 times the Base Self-Disclosure Repayment. The FCA allows up to three times damages plus per-claim penalties. - The gate is "previously unknown to the federal government." If the government already knows, the pilot is off the table. - Civil only. Potential criminal conduct goes to DOJ's National Fraud Enforcement Division under a separate policy. - Submissions go to FCA-SDPP@usdoj.gov by 11:59 PM on April 22, 2027. Late or partial submissions will not be accepted or reviewed. - The 60-day overpayment rule at 42 C.F.R. 401.305 keeps running. Chapters: 0:00 Cold open 0:27 What happened 4:55 Why it matters 7:57 Practical checklist 10:13 My take 10:48 Disclaimer and close Sources: DOJ/HHS FCA SDPP protocol (PDF): https://www.justice.gov/opa/media/1467546/dl DOJ press release, Oct 22, 2026: https://www.justice.gov/opa/pr/justice-departments-civil-division-and-department-health-human-services-announce-anti-fraud HHS press release, Oct 22, 2026: https://www.hhs.gov/press-room/hhs-doj-launch-healthcare-false-claims-act-self-disclosure-pilot.html This episode is educational commentary and is not legal advice. Andrew Hillman is not an attorney. Talk to qualified counsel about your specific situation. Narrated by an AI voice (synthetic narration). No real person's voice or likeness is used. Links and resources: The Letter: https://thehillmanletter.substack.com/p/fca-self-disclosure-pilot Podcast home: https://andrew-hillman.com/podcast/ About the host: https://andrew-hillman.com/who-is-andrew-jonathan-hillman/ LinkedIn: https://www.linkedin.com/in/andrew-hillman-dallas The Hillman Letter on Substack: https://thehillmanletter.substack.com Apple Podcasts: https://podcasts.apple.com/us/podcast/the-hillman-letter-podcast/id6825615190 Spotify: https://open.spotify.com/show/2ZYUBaVrUxWDAhskCNTXzs YouTube episode: https://www.youtube.com/watch?v=G2yFNQTmNQA YouTube playlist: https://www.youtube.com/playlist?list=PLElpO9MC9VC4 Academia.edu, SMU: https://smu.academia.edu/AndrewHillman ORCID: https://orcid.org/0009-0001-5396-321X Wikipedia: https://en.wikipedia.org/wiki/Andrew_Jonathan_Hillman Book a call: https://calendly.com/ajhusa Educational only. Not legal advice. Not an attorney.