The Department of Justice (DOJ) announced recently that settlements and judgments under the False Claims Act (FCA) exceeded $6.8 billion in the fiscal year ending September 30, 2025 — the highest single-year total in the statute’s history. The announcement underscores the continued centrality of the FCA in the federal government’s fraud-enforcement arsenal.
Since Congress substantially strengthened the FCA in 1986, total recoveries now exceed $85 billion, a figure that reflects both sustained enforcement priorities and the growing role of whistleblowers in uncovering alleged fraud against the government.
Link to A Surge in Whistleblower Activity and Investigations A Surge in Whistleblower Activity and Investigations
Fiscal year 2025 also set new records for enforcement activity. Whistleblowers filed 1,297 qui tam lawsuits, surpassing the prior record of 980 filings set just last year. At the same time, the government opened 401 new FCA investigations, including matters aligned with stated administration policy objectives.
Link to Healthcare Fraud Dominates Recoveries Healthcare Fraud Dominates Recoveries
As in prior years, healthcare fraud accounted for the majority of recoveries. Of the more than $6.8 billion recovered in FY 2025, over $5.7 billion arose from matters involving the healthcare industry, including losses to Medicare, Medicaid, and TRICARE.
DOJ identified three areas in which it continued to expand enforcement success: (1) Managed Care, (2) Prescription Drugs, and (3) Medically Unnecessary Care.
While the reported figures reflect only federal losses, DOJ noted that many of these matters also resulted in substantial recoveries for state Medicaid programs.
Link to Procurement, Cybersecurity, Pandemic, and Trade Fraud Remain Priorities Procurement, Cybersecurity, Pandemic, and Trade Fraud Remain Priorities
DOJ also continued to pursue FCA matters involving government procurement and grants, particularly where the alleged fraud affected the military or implicated national security concerns. DOJ reaffirmed its focus on knowing violations of cybersecurity requirements, as well as recovering hundreds of millions of dollars lost to fraud in pandemic-related programs.
In addition, DOJ highlighted increased enforcement targeting tariff and customs duty evasion, including the launch of a cross-agency Trade Fraud Task Force. These cases focus on alleged schemes involving misclassification of goods, false country-of-origin claims, or other efforts to evade lawful duties — conduct DOJ views as undermining domestic industries, consumer confidence, and national security.
Link to Cooperation and Self-Disclosure Continue to Pay Dividends Cooperation and Self-Disclosure Continue to Pay Dividends
Consistent with recent enforcement guidance, DOJ reiterated its commitment to incentivizing self-disclosure, cooperation, and remediation. Several settlements in FY 2025 reflected tangible cooperation credit, including reduced penalties or damage multipliers for entities that promptly disclosed misconduct, assisted in calculating government losses, shared internal investigative findings, or implemented meaningful compliance enhancements.
For contractors and healthcare providers, this continues to reinforce a critical point: Proactive compliance, early self-assessment, and strategic engagement with the government can materially affect outcomes in FCA investigations.
Link to Qui Tam Actions Drive Enforcement Qui Tam Actions Drive Enforcement
Qui tam actions — lawsuits brought by private individuals known as “relators” or whistleblowers — remain the backbone of FCA enforcement. In FY 2025, DOJ reported more than $5.3 billion in settlements and judgments arising from qui tam cases, including both newly filed and earlier actions.
When such cases succeed, whistleblowers typically receive 15% to 30% of the recovery, a powerful incentive that continues to drive record-level filings.
Link to Looking Ahead Looking Ahead
The record-breaking recoveries announced by DOJ signal that the department intends to continue deploying the FCA aggressively — particularly in healthcare, procurement, cybersecurity, and trade — while rewarding cooperation and self-disclosure.
For entities doing business with the federal government, the message is clear: FCA risk is not theoretical, enforcement trends are accelerating, and compliance failures — especially those flagged by insiders — carry unprecedented financial and operational consequences.
If you have any questions regarding strategies to prevent or address potential FCA issues, please do not hesitate to contact Aron Beezley or Nathaniel Greeson.