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The U.S. Attorney's Office for the Eastern District of Pennsylvania announced the implementation of its White Collar Justice Program in September 2025, a move that reaffirmed the office's public commitment to white collar enforcement under U.S. Attorney David Metcalf.

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Metcalf was nominated for the role in March 2025 and appointed to the role in June by the U.S. District Court for the Eastern District of Pennsylvania prior to his confirmation by the U.S. Senate in October.

Metcalf has made clear that white collar enforcement is a major focus of the office under his leadership, and he is committed to aggressively pursuing investigations and prosecutions involving healthcare, securities fraud, public corruption and other traditional white collar criminal violations in the Eastern District of Pennsylvania.

This article discusses the office's commitments and priorities under Metcalf, surveys early results from his first year leading the office, and provides compliance pointers for companies and their counsel operating under the office's jurisdiction.

Corporate Transparency Initiative

A cornerstone of the office's White Collar Justice Program is the voluntary self-disclosure program. An implementation of the nationwide, uniform corporate self-disclosure program established by the U.S. Department of Justice in March, it allows companies that discover illegal activity the opportunity to disclose it in exchange for certain benefits.

The program has two tiers: the first tier — which requires disclosure before detection, full investigative cooperation, timely and appropriate remediation, and the absence of any aggravating factors&nbsp;— allows a company to avoid prosecution entirely, while the second tier allows for reduced penalties and potential exemption from monitorship.

Metcalf, who has previously worked in-house, is likely sympathetic to company concerns about self-reporting to the DOJ. With that in mind, the voluntary self-disclosure program seeks to provide concrete incentives to corporate clients and their counsel who report issues as early as possible after discovery of a potential violation.

The office is encouraging corporate counsel to contact the Eastern District of Pennsylvania unit supervisors directly on an informal basis in advance of self-disclosure, at which time they can test the waters by engaging in hypothetical conversations at an early stage without providing client names or identifying details.

In addition to the voluntary self-disclosure&nbsp;program, the U.S. Attorney's Office is actively seeking to tackle investigations and enforcement matters that involve healthcare companies and providers, Fortune 500 public companies, and financial institutions, given the number and size of those entities with operations in the Eastern District of Pennsylvania.

Healthcare Fraud

The district is a major hub for the healthcare industry, and it handles a significant qui tam/False Claims Act docket. Metcalf has emphasized that he intends the office to be a leader in healthcare fraud enforcement. Concrete steps his office is taking include:

Reconstituting the DOJ's Health Care Fraud Strike Force model in Philadelphia, including embedding trial attorneys from Main Justice in the Eastern District of Pennsylvania, hiring additional prosecutors&nbsp;and assigning the top assistant U.S. attorneys&nbsp;in the district to work on healthcare fraud matters;

Leveraging the office's qui tam/FCA docket via the Government Fraud Alliance, in which civil and criminal assistant U.S. attorneys work together from the inception of a civil FCA filing to determine whether there is a basis to pursue a criminal case as well; and

Renewing the office's commitment to promptly and aggressively investigate potential criminal conduct&nbsp;along with the civil qui tam investigation — these efforts will take place under new leadership and increased staffing in the FCA qui tam program.

Companies in the healthcare sector should prepare for an increase in investigations, as the Eastern District of Pennsylvania office seeks to encourage internal whistleblowers to file FCA cases in the district.

Investor and Securities Fraud

The office is increasing its focus on source cultivation as a means of generating cases. With respect to securities fraud matters, this includes:

Reviewing open-source material and the civil litigation docket in the Eastern District of Pennsylvania federal courts&nbsp;—&nbsp;assistant U.S. attorneys are instructed to immerse themselves in the news and developments emerging from Wall Street and the financial system,&nbsp;and to act without hesitation if they see a basis for criminal investigation;

Actively partnering with financial regulators at the local and national level, as well as taking on cases that the U.S. Securities and Exchange Commission&nbsp;may have developed in a different office or region; and

Engaging with the legal and business communities both within and outside the district.

Public Corruption

The Eastern District of Pennsylvania office has traditionally been known for its public corruption prosecutions, and Metcalf has pledged to uphold that tradition. Metcalf has emphasized the need for his office to establish relationships and maintain dialogues such that individuals who know or learn about offense conduct feel comfortable reporting it.

In one recent example, on Feb. 9, the Eastern District of Pennsylvania office announced the indictment of Samuel D. Marcus, a U.S. Department of Defense employee, on charges of conspiracy to commit money laundering, illegal monetary transactions and illegal concealment. The indictment in U.S. v. Marcus alleges that the employee served as a "money mule" for a group of Nigerians who targeted victims based in the U.S. in a variety of wire fraud schemes. Marcus pled not guilty to the charges.

Looking Beyond the Eastern District

Metcalf has made clear that, in addition to local matters and offenses, he would like his office to compete for nationally significant white collar matters with ties to the Eastern District of Pennsylvania. Metcalf has sought to revamp the office's culture around case origination, encouraging assistant U.S. attorneys to proactively and aggressively seek out new matters. That cultural transformation will be effectuated through the office's structure, its hiring strategy, and the policies and programs that it implements.

Notable Enforcement Activities

A survey of the corporate enforcement activities during Metcalf's tenure so far demonstrates the office's continued focus on the FCA and healthcare fraud in particular. Resolutions announced over the last several months involve entities based in the Eastern District of Pennsylvania, but also extend to matters with a national scope. A few recent examples are detailed below.

ProMedica Health System

On Sept. 2, 2025, the office announced that it was intervening in a whistleblower action against Ohio-based ProMedica Health System Inc. and various affiliated entities, including HCR ManorCare Inc. and four nursing homes located in Pennsylvania, Ohio, South Carolina and Virginia. The complaint alleges that the facilities failed to provide adequate care and that the defendants falsely documented in medical records that care and services had been provided to residents when they had not been.

On Dec. 16, 2025, the office announced a $1.5 million settlement with RST-Sanexas Inc., a Las Vegas-based manufacturer and marketer of electric stimulation devices, and its principal owners. The settlement resolved allegations that Sanexas caused the submission of false claims to Medicare for electrical muscle stimulation, vitamin injections and other services that were not medically necessary, and that the claims were tainted by impermissible kickbacks.

In a statement, Metcalf noted that the office was "continu[ing] to lead the national charge to hold alleged fraudsters accountable for improper Sanexas billing."

On Jan. 21, 2026, the Eastern District of Pennsylvania office announced the sentencing of an individual charged in the district with defrauding investors out of approximately $5 million. Henry Ford, also known as Cleothus "Lefty" Jackson, pled guilty last May. The office spearheaded the criminal prosecution, even though the defendant was a Florida resident, took meetings in New Jersey and was investigated by the SEC's New York regional office. The press release noted that the defendant had coordinated outreach to investors through an acquaintance based in the Eastern District of Pennsylvania.

On March 10, the Eastern District of Pennsylvania office announced a $117.7 million settlement with Aetna Inc., which resolved allegations that Aetna had violated the FCA by submitting or failing to withdraw inaccurate and untruthful diagnosis codes for Medicare Advantage Plan enrollees, which the government alleged had improperly inflated the payments Aetna received from the Centers for Medicare &amp; Medicaid Services. The settlement also resolved a qui tam suit by a former Aetna risk-adjustment coding auditor, with the whistleblower set to receive a $2,012,500 share of the settlement amount.

Key Takeaways and Suggestions for Corporate Clients and Practitioners

The Eastern District of Pennsylvania office appears to be sharpening its focus on white collar enforcement, particularly with respect to healthcare fraud, securities fraud and public corruption.

The voluntary self-disclosure program is a key part of Metcalf's agenda and may offer a potential route to corporate clients in certain situations that are looking to avoid prosecution, high penalties and burdensome monitoring.

The office's emphasis on and expansion of its national reach also means that both&nbsp;corporate clients based in the Eastern District of Pennsylvania, as well as&nbsp;those with facilities, subsidiaries or affiliates based in the district,&nbsp;should be paying close attention to the office's enforcement priorities.

In light of the office's renewed emphasis on white collar enforcement, particularly in the areas detailed above, we recommend that companies doing business in or around the Eastern District of Pennsylvania consider the following steps:

Keep abreast of enforcement trends within your industry.

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Monitor compliance hotline calls, particularly in light of the office's encouragement of qui tam complaints. Employee, customer/client&nbsp;and whistleblower complaints should be investigated promptly and properly — ignoring internal warning signs can lead to much greater company and personal risk, expense, and agita&nbsp;if the government takes action first.

Engage in compliance checkups, including checks on policies and procedures related to regulatory compliance and employee compliance training, and follow the appropriate steps upon receipt of a subpoena or investigative demand.

Keep an eye out for any further announcements related to the voluntary self-disclosure program. The office has yet to announce any resolutions derived from that program, but, if and when it does so, it will provide additional guidance on how that program is being used and whether certain clients may benefit from it.

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"Mapping Philly U.S. Atty's White Collar Enforcement Push," by Joseph G. Poluka, Jennifer A. Short, and Rebecca L. Orel was published in&nbsp;<a href="https://www.law360.com/articles/2468266">Law360</a>&nbsp;on April 28, 2026. Reprinted with permission.

Mapping Philly U.S. Atty’s White Collar Enforcement Push

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Mapping Philly U.S. Atty’s White Collar Enforcement Push

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