by Ericka Aiken, Kevin Lamb, and Audrey Sapirstein

From Left to Right: Ericka Aiken, Kevin Lamb, and Audrey Sapirstein. (Photos courtesy of Wilmer Cutler Pickering Hale and Dorr LLP)
Introduction
On January 8, 2025, the U.S. Department of Justice (DOJ) announced that a federal grand jury indicted the Chesapeake Regional Medical Center (CRMC) in Virginia for conspiracy to defraud the United States and health care fraud. In this rare move, DOJ seeks to hold a hospital criminally responsible for alleged fraudulent conduct committed by a physician at the hospital. The indictment alleges that from 2010 to 2019, CRMC and a former obstetrician-gynecologist with surgical privileges at CRMC conspired to defraud the government by performing medically unnecessary operations, submitting inaccurate and false bills, and failing to comply with applicable rules and regulations. According to the indictment, CRMC received approximately $18.5 million in reimbursements from health care benefit programs over that time for procedures performed by the former physician at the hospital.