False Claims Act Recoveries Reach Record $6.8 Billion in Fiscal Year 2025
The United States Department of Justice ("DOJ") reports record-setting False Claims Act ("FCA") recoveries reflecting the administration's continued use of the statute.
The DOJ announced that settlements and judgments under the FCA exceeded $6.8 billion in fiscal year 2025, marking the highest annual recovery in the statute's history. This record reflects intensified enforcement efforts, particularly in the health care sector, and underscores the FCA's continued role as a primary tool for combating fraud against the federal government.
Key Developments
- Record Enforcement Activity: In FY 2025, whistleblowers filed 1,297 qui tam lawsuits, the highest number ever recorded and a 32 percent increase from the 980 filed in FY 2024. The government also opened 401 investigations of its own, 183 of which involved the healthcare industry.
- Health Care Fraud Continues to Dominate: Of the $6.8 billion, over $5.7 billion resulted from health care matters. Approximately $2.8 billion of that resulted from only three verdicts that are pending on appeal. Enforcement focused heavily on allegations concerning prescription drugs, including a nearly $1 billion judgment against a pharmacy and more than $660 million in settlements with pharmaceutical manufacturers related to alleged copay kickbacks and speaker programs.
- Whistleblower Impact: $4.5 billion of the $5.7 billion recovered from health care matters (nearly 79 percent) was recovered through qui tam cases. And notably, in 2025 whistleblowers in health care matters recovered more in cases where the government declined to intervene ($2.27 billion), than in cases it intervened in ($2.225 billion).
- Reported Incentives for Cooperation: DOJ emphasized its commitment to incentivizing self-disclosure and cooperation, noting that several settlements reflected credits, resulting in reduced payments, for parties who self-reported misconduct, assisted in investigations, and/or implemented remedial measures.
Implications
Given the increases in FCA recoveries, the volume of FCA cases, and the massive potential exposure for entities directly or indirectly receiving federal funds, parties should carefully evaluate all strategic options, ranging from self-disclosure and cooperation to active litigation, when responding to FCA allegations.