DOJ Reports Record-Breaking Year for False Claims Act Settlements

In a historic achievement, the Department of Justice secured over $6.8 billion in False Claims Act settlements and judgments during the fiscal year ending September 30, 2025. This record-breaking figure easily surpasses the previous high of $6.1 billion set in 2014, marking the largest annual recovery in the Act’s history.

The past year saw unprecedented growth in both recovery amounts and case volume. Whistleblower activity reached new heights, with relators filing 1,297 qui tam cases—exceeding last year’s record by more than 300 cases. Simultaneously, the Justice Department maintained its proactive approach, initiating 401 new FCA matters without relator involvement, its third highest total ever.

Healthcare fraud dominated the recovery landscape, accounting for approximately $5.7 billion of the total. The DOJ’s enforcement efforts in this sector concentrated on three primary areas: managed care fraud, prescription drug violations, and medically unnecessary services. Several significant jury verdicts contributed substantially to these figures, including a $1.6 million judgment in a pharmaceutical case and a $948.8 million verdict against a pharmacy.

Beyond healthcare, the Justice Department targeted fraud in government procurement, tariff and customs violations, cybersecurity requirement breaches, and pandemic program fraud, reflecting the agency’s broad enforcement priorities.

Despite the record-breaking total recoveries and unprecedented number of qui tam filings, whistleblower compensation showed a surprising decline. While overall settlements and judgments increased by 119% in fiscal year 2025, relator share awards dropped by 31%. Whistleblowers received approximately $330 million in total—the second lowest amount since 2009—from over $5.3 billion in qui tam case recoveries.

This translates to relators receiving an average of just 6% of total recoveries, significantly below the statutory range of 15% to 30% established in the False Claims Act. The substantial gap between the statutory provisions and actual payments raises questions about the distribution of recovered funds.

The reason for this disparity remains unclear. Possible explanations include a higher proportion of settlements and judgments not being directly attributable to whistleblowers’ original claims, or that relator share determinations in some major cases have yet to be finalized.

Particularly noteworthy is the success whistleblowers achieved in healthcare cases without government support. For only the second time in history—the first being in 2022—relators recovered more in cases where the government declined to intervene ($2.27 billion) than in cases with government intervention ($2.23 billion).

This trend suggests growing sophistication among whistleblower legal teams and potentially signals a shift in the traditional dynamic between private relators and government prosecutors in pursuing fraud against federal programs.

The record-setting year reflects the continuing effectiveness of the False Claims Act as the government’s primary civil enforcement tool against fraud. It also highlights the critical role whistleblowers play in identifying and pursuing fraudulent activities that might otherwise go undetected.

As enforcement priorities evolve and new fraud schemes emerge, the Justice Department’s aggressive use of the False Claims Act appears likely to continue, particularly in healthcare and government procurement—areas that consistently yield the highest recoveries for taxpayers.

The apparent disconnect between increased case filings and recoveries versus decreased whistleblower compensation bears watching, as it could potentially impact future whistleblower participation in the qui tam system that has proven vital to the government’s anti-fraud efforts.