Key False Claims Act Trends Over the Past Year

In a year marked by shifting priorities under the Trump administration, False Claims Act enforcement remained robust in 2025, maintaining its focus on healthcare fraud while simultaneously exploring new avenues for application, according to legal experts.

Federal prosecutors continued their aggressive pursuit of healthcare fraud cases, which have historically dominated False Claims Act litigation. Despite predictions of a potential pullback in enforcement, the Justice Department actually increased its recovery totals compared to the previous administration’s final year, securing over $3.2 billion from settlements and judgments involving alleged fraud against the government.

“What we’re seeing is continuity in core enforcement areas with strategic pivots that reflect the administration’s priorities,” said Raymond Moss, a partner at Wilson & Schmidt specializing in government enforcement defense. “Healthcare remains the primary target, but the scope is definitely expanding.”

The pharmaceutical sector faced particular scrutiny, with major settlements involving allegations of kickback schemes and off-label marketing. Three of the year’s largest recoveries came from pharmaceutical manufacturers, including a $420 million settlement with a leading diabetes drug maker over alleged improper relationships with prescribing physicians.

Hospital systems also remained under the microscope, with investigators targeting improper billing practices, particularly in Medicare Advantage programs. Rural hospitals faced heightened scrutiny over billing practices, with seven settlements announced in the final quarter of 2025 alone.

Defense contractors, another traditional focus of False Claims Act enforcement, saw consistent attention. The Justice Department recovered approximately $580 million from defense and aerospace companies for alleged violations ranging from defective product delivery to labor mischarging on government contracts.

What distinguished 2025’s enforcement landscape, however, was the expansion into new priority areas. The administration showed increased interest in targeting immigration services contractors, with three significant cases alleging substandard detention conditions and falsified compliance records at privately operated detention facilities.

“The shift toward immigration-related contractors represents a clear policy directive from the White House,” explained Maria Chen, former assistant U.S. Attorney and current law professor at Georgetown. “The administration is using the False Claims Act as one tool among many to address what it considers immigration enforcement priorities.”

Cybersecurity compliance also emerged as a growing enforcement focus. The Justice Department pursued multiple cases against government contractors alleged to have misrepresented their cybersecurity protocols and capabilities, including a landmark $95 million settlement with a major IT service provider that allegedly failed to implement required security measures on federal systems.

Qui tam lawsuits—cases initiated by whistleblowers—continued to drive a significant portion of enforcement actions. Of the 715 new False Claims Act cases filed in 2025, approximately 75% originated from whistleblowers, according to Justice Department data. Whistleblower awards totaled nearly $490 million, providing significant incentives for insiders to report potential fraud.

“Whistleblower-initiated cases remain the engine driving False Claims Act enforcement,” said Veronica Nannis, a prominent whistleblower attorney. “The administration has recognized their value in identifying fraud that might otherwise go undetected.”

Legislative developments also shaped the enforcement landscape. In September 2025, Congress passed amendments strengthening the government’s ability to pursue materiality arguments in False Claims Act cases, partially addressing issues raised in previous Supreme Court decisions that had limited the government’s reach.

Corporate compliance officers across industries have taken notice of the sustained enforcement pressure. A recent survey by the Compliance Professionals Association found that 68% of responding companies had increased their compliance budgets specifically for False Claims Act risk management.

Looking ahead to 2026, legal experts anticipate continued robust enforcement with increasing focus on the administration’s priority areas. The Justice Department has signaled interest in expanding investigations into government-funded infrastructure projects, with particular attention to domestic sourcing requirements and labor practices.

As the administration continues to shape its enforcement agenda, companies doing business with the federal government face sustained pressure to ensure rigorous compliance programs and internal controls to prevent potential False Claims Act liability.