DOJ Reports Record Year for False Claims Act Recoveries in 2025

Record $6.8 Billion in False Claims Act Recoveries Signals Expanded Enforcement Agenda

The Department of Justice has announced unprecedented False Claims Act recoveries for fiscal year 2025, collecting over $6.8 billion in judgments and settlements. The figure more than doubles the previous year’s $3.1 billion in recoveries and approaches the all-time high set in 2014 during the aftermath of the housing crisis.

Healthcare fraud dominated the government’s recovery efforts, accounting for $5.7 billion of the total. The healthcare recoveries included a landmark $1.6 billion verdict against pharmaceutical giant Janssen Products in a whistleblower-initiated lawsuit, marking the largest single verdict in the statute’s history. The remaining recoveries came from cases involving procurement and grant fraud, tariff and customs violations, and an emerging area of focus – cybersecurity fraud.

While the financial totals are striking, legal experts are particularly focused on the dramatic surge in whistleblower activity. The Justice Department reported 1,297 new qui tam cases filed by whistleblowers in 2025, shattering the previous record of 980 cases set just a year earlier in 2024. Most of these cases remain under seal pending government investigation.

“Two consecutive years of record-breaking whistleblower filings suggests we’re entering a new era of False Claims Act litigation,” said Amanda Benson, partner at Davidson & Wells, a law firm specializing in government compliance. “Companies with federal contracts or who receive government funding should be reviewing their compliance programs immediately.”

The back-to-back increase in whistleblower cases foreshadows a substantial rise in false claims litigation expected to unfold throughout 2026 and beyond. This trend represents a significant shift in the enforcement landscape that could affect thousands of companies across multiple industries.

In its press release, the Justice Department emphasized its intention to leverage the False Claims Act to advance the administration’s “America First” policy objectives. These initiatives include targeting what officials describe as illegal diversity, equity, and inclusion (DEI) programs, combating antisemitism, and restricting gender-affirming healthcare services.

While administrations have historically used the False Claims Act to support policy priorities, these particular initiatives represent a notable expansion of the statute’s application. Legal scholars note this broadened approach could introduce novel legal theories that create additional compliance risks for organizations receiving federal funds.

“Using the False Claims Act as a tool to enforce political and social policy goals raises significant questions about the statute’s scope,” explained Robert Chen, professor of government contracting law at Georgetown University. “We’re seeing the potential emergence of a more expansive interpretation that could affect universities, healthcare providers, and government contractors in ways not previously contemplated.”

The False Claims Act, originally enacted during the Civil War to combat defense contractor fraud, imposes liability on entities that defraud governmental programs. Modern amendments have strengthened whistleblower provisions, allowing private citizens with knowledge of fraud to file lawsuits on the government’s behalf and share in any recovery.

For companies in the healthcare sector, which has long been the primary target of False Claims Act enforcement, the record recoveries signal continued aggressive scrutiny. Major pharmaceutical manufacturers, hospital systems, and medical device companies face particular exposure given the massive federal spending in these areas through Medicare and Medicaid programs.

Market analysts predict the heightened enforcement climate could lead to more conservative billing practices and increased investment in compliance infrastructure across industries that rely on government funding. Some executives are already reporting allocating additional resources toward auditing internal procedures and strengthening compliance programs.

As the Justice Department continues to unseal and pursue the backlog of whistleblower cases filed over the past two years, organizations receiving federal funds will need to carefully navigate an increasingly complex regulatory landscape characterized by both traditional fraud concerns and emerging policy-driven enforcement priorities.