Contributors

On March 16, 2026, President Donald Trump signed an executive order establishing the Task Force to Eliminate Fraud, a White House-led initiative chaired by Vice President J.D. Vance that will coordinate government-wide efforts to combat fraud, waste, and abuse in federal benefit programs. 

The Task Force includes representatives from nearly a dozen federal agencies, including the Departments of Treasury, Justice, Agriculture, Labor, Health and Human Services, Housing and Urban Development, Education, Veterans Affairs, and Homeland Security, as well as the Small Business Administration and the Office of Management and Budget. 

These initiatives signal a significant escalation in anti-fraud enforcement that companies receiving federal funds or participating in federally funded programs should monitor closely. This includes Tribal Nations, which may fall within the scope of the seminal statute, Title 18, United States Code, Section 666, Theft or Bribery concerning programs receiving Federal funds. Section 666 applies to a host of offense conduct including embezzlement, theft, conversion, bribery, intentional misapplication, and fraud.

Timeline and Priorities

The executive order directs the Task Force to coordinate a comprehensive national strategy to stop fraud, waste, and abuse across federal benefit programs, including housing, food, medical care, and cash assistance administered with state and local partners, in order to protect these benefits for eligible Americans. 

The Task Force's stated priorities include improving eligibility verification, implementing pre-payment controls, detecting high-risk fraud trends, and disrupting and dismantling fraud networks and the mechanisms through which fraud is committed. Notably, Section 6 of the executive order directs the Task Force to promote the meritorious pursuit of qui tam actions under the False Claims Act (31 U.S.C. § 3730) involving fraud in federal benefit programs, and to ensure prompt review of those actions within 60 days.

The order establishes the following implementation timeline:

  • Within 30 days, each member agency must identify benefit transactions and processes most susceptible to fraud, such as new enrollments, eligibility self-attestation procedures, and transactions involving third-party intermediaries, and submit suggested preventive measures.
  • Within 60 days, the Task Force will coordinate adoption of minimum anti-fraud requirements, including identity verification, documentation requirements, risk controls, and audit and remedial actions. The Task Force will also address how state and local jurisdictions administering federal funds can demonstrate compliance with these requirements.
  • Within 90 days, each Task Force member must submit a measurable implementation plan.

Connection to DOJ's Division for National Fraud Enforcement

The Task Force builds on the Trump Administration's earlier announcement in January 2026 creating DOJ's new Division for National Fraud Enforcement, which will be led by  a new Assistant Attorney General responsible for leading efforts to investigate, prosecute, and remedy fraud affecting the federal government, federally funded programs, and private citizens. This role will oversee multi-district and multi-agency fraud investigations, provide advice and direction to U.S. Attorneys' Offices on fraud-related issues, and work closely with federal agencies to identify, disrupt, and dismantle organized and sophisticated fraud schemes across jurisdictions. 

The Administration has already demonstrated its commitment to aggressive fraud enforcement. DOJ is currently engaged in active investigations into Medicaid fraud schemes in Minnesota, with the FBI deploying forensic accountants and data analytics teams to investigate health care and home care providers.

The establishment of the Task Force to Eliminate Fraud, combined with the new DOJ Division for National Fraud Enforcement, signals a significant escalation in federal anti-fraud enforcement. Companies and Tribal Nations receiving federal funds or participating in federally funded programs should closely monitor these developments and take proactive steps to strengthen their compliance posture.

Key Takeaways 

  • Expect heightened scrutiny. Companies and Tribal Nations operating in sectors involving federal funds, including healthcare providers, higher education institutions, defense and infrastructure contractors, small business loan recipients, and federally supported nonprofits, should anticipate increased examination of their certifications, reporting, and compliance with eligibility requirements.
  • Assess False Claims Act exposure. Companies should proactively evaluate their exposure under the False Claims Act and related civil and criminal fraud statutes, particularly given the executive order's emphasis on promoting qui tam enforcement (31 U.S.C. § 3730) and the rise of DOJ Whistleblower Incentives.
  • Review internal controls. Organizations should consider strengthening compliance programs around federal benefits eligibility verification, reviewing internal controls over federal funds, and ensuring accurate documentation of services provided.
  • Prepare for coordinated enforcement. The multi-agency approach increases the likelihood that patterns of conduct, rather than isolated incidents, will drive investigations. Early identification and remediation of potential compliance issues will be critical.

Womble Bond Dickinson (US) LLP’s White Collar Defense and Criminal Investigations Team navigates domestic and international clients in all manner of white collar, regulatory, corporate and congressional investigations. Our team includes a distinguished roster of veteran defense attorneys, former federal prosecutors and U.S. Attorneys who served at the highest levels of the Department of Justice and at leading United States Attorneys’ Offices. Our team includes Chambers Ranked (Band 1) lawyers and alumni of the U.S. Department of Justice, the SEC’s Enforcement Division, the U.S. Senate, House of Representatives, and in-house compliance specialists of publicly traded companies.