Alexis Gregorian Quoted in Part B News on Expanded Healthcare Fraud Self-Disclosure Options

Bradley partner Alexis Gregorian was quoted in Part B News in an article about the importance of healthcare organizations strengthening and publicizing their internal compliance reporting structures.

Gregorian warned that the new DOJ whistleblower incentive program gives employees additional motivation to report suspected misconduct directly to federal authorities rather than raising concerns internally.

“The concern for practices is that an employee may approach DOJ before management learns of the issue or finishes investigating,” Gregorian said.

She added, “Providers should not assume whistleblowers will report internally first — they now have greater incentive to bypass that step and go straight to DOJ.”

Gregorian also cautioned that organizations should understand the eligibility requirements for the new self-disclosure programs.

“The best investment an entity can make” in this regard, Gregorian said, “is in publicizing their internal reporting structure to employees.”

Eligibility for the self-disclosure programs generally depends on misconduct being previously unknown to DOJ. The new whistleblower incentive program could make that requirement harder to meet if an employee reports suspected misconduct before the organization has an opportunity to investigate or disclose it.

The full article, “Amid DOJ and OIG Retool, New Self-Disclosure Rules Broaden Options,” was published by Part B News on November 9, 2026. (login required)