The U.S. Department of Justice (“DOJ”) has released its annual statistics on enforcement under the federal False Claims Act (“FCA”), reporting more than $6.8 billion in settlements and judgments for fiscal year (“FY”) 2025, the largest single‑year recovery in the statute’s history. The report reflects record whistleblower activity, the continued dominance of health care enforcement, and DOJ’s expanding use of the FCA in procurement, cybersecurity, pandemic relief, and trade matters. Below, we highlight the most significant takeaways from DOJ’s FY 2025 report and discuss what they mean for companies doing business with, or receiving funds from, the federal government.
Record‑Breaking Recoveries and Qui Tam Filings
According to DOJ, FCA settlements and judgments exceeded $6.8 billion in FY 2025, surpassing the prior record of $6.2 billion set in 2014 and dramatically increasing from recoveries reported in FY 2023 ($2.68 billion) and FY 2024 ($2.9 billion). Total FCA recoveries now exceed $85 billion since Congress strengthened the statute in 1986 to include increased penalties, qui tam provisions, and a broader claim coverage.
Whistleblowers filed 1,297 qui tam lawsuits in FY 2025 – the highest number ever recorded. Recoveries attributable to qui tam actions totaled more than $5.3 billion, reaffirming DOJ’s continued reliance on relators as the primary driver of FCA enforcement.
Health Care Continues to Drive FCA Enforcement
As in prior years, health care fraud dominated FCA recoveries. DOJ reported that over $5.7 billion of the $6.8 billion total recoveries involved health care matters, impacting programs such as Medicare, Medicaid, and TRICARE.
DOJ highlighted three recurring areas of focus:
- Managed Care and Medicare Advantage (Part C): Enforcement actions targeted allegedly unsupported diagnosis codes and kickback‑based enrollment practices, including multiple large settlements with insurers and provider groups.
- Prescription Drugs and Pharmacies: DOJ pursued alleged misconduct involving pricing, copay assistance, speaker programs, and dispensing without valid prescriptions, resulting in several nine‑figure settlements and verdicts.
- Medically Unnecessary Services and Substandard Care: FCA cases continued to pair billing allegations with claims that patient care was unnecessary or inadequate, a theory DOJ has increasingly emphasized in recent years.
Notably, the amounts reported reflect only federal losses; many of these matters also resulted in additional recoveries for state Medicaid programs, underscoring the continued coordination between DOJ and state attorneys general.
Procurement Fraud, Cybersecurity, and Defense Contracting
Beyond health care, DOJ reported significant FCA activity involving federal procurement and defense contracts, including one of the largest procurement fraud settlements in DOJ history. Multiple matters focused on defective pricing, submission of false cost or pricing data, failure to meet contract specifications, and improper billing practices by government contractors.
The report also underscores DOJ’s growing use of the FCA to police cybersecurity compliance. In FY 2025 alone, DOJ recovered more than $52 million through civil cyber‑fraud settlements and noted that cybersecurity settlements have more than tripled over the past two years. These cases frequently allege that contractors or grantees falsely certified compliance with contractual or regulatory cybersecurity requirements or provided the federal government with cybersecurity products that contained vulnerabilities or an adequate cybersecurity program.
Continued Focus on Pandemic Relief and Trade Fraud
DOJ continues to invest resources in FCA cases involving pandemic‑era relief programs, including the Paycheck Protection Program and other COVID‑19 assistance initiatives. These claims involved submission of false information (such as employee rosters or payrolls) when seeking PPP loans or falsified claims for loan forgiveness, or falsified claims under pandemic-related healthcare programs. Recoveries from pandemic‑related matters remain substantial, signaling that these investigations will persist for years to come.
In addition, in August of 2025 DOJ announced the formation of a cross‑agency, the Trade Fraud Task Force, reflecting increased FCA enforcement aimed at evasion of tariffs and customs duties, including misclassification of goods and misrepresentations regarding country of origin. The Task Force is a cooperative effort between DOJ and the Department of Homeland Security (“DHS”) and identified the FCA as one of its primary enforcement tools. The Task Force press release specifically requested whistleblowers utilize the qui tam provisions of the FCA to call out potential fraud. This initiative marks an expansion of FCA enforcement into areas traditionally associated with customs and trade regulation.
DOJ Reemphasizes Cooperation and Self‑Disclosure
Consistent with recent policy statements, DOJ reiterated its commitment to rewarding companies that self‑disclose misconduct, cooperate with investigations, and implement effective remediation. Several FY 2025 settlements cited such efforts as a basis for reduced damages or penalties, reinforcing DOJ’s expectation that regulated entities take proactive compliance and remediation seriously.
Key Takeaways for Regulated Entities
The FY 2025 FCA report reinforces several practical lessons for companies operating in heavily regulated or federally funded environments:
- Expect continued FCA scrutiny, particularly in health care, defense contracting, cybersecurity compliance, and trade‑related activities.
- Whistleblower risk remains high, given record qui tam filings and DOJ’s continued dependence on relators.
- Compliance certifications matter – especially in pricing, cybersecurity, and federal procurement – and inaccuracies may form the basis of FCA liability.
- Early engagement with counsel, self‑disclosure, and remediation can meaningfully affect enforcement outcomes and potential exposure.
In addition to the headline recovery figures, DOJ’s enforcement messaging and structural changes suggest meaningful new FCA risk tied to eligibility and certification‑based representations, including in areas related to diversity, equity, and inclusion (“DEI”). DOJ has increasingly signaled that misstatements concerning eligibility for government programs, grants, or contracting preferences – such as ownership, control, or compliance with program requirements – may be material for FCA purposes, even where the underlying contract work or services were performed. At the same time, DOJ’s recent creation of a National Fraud Division points toward more centralized, coordinated, and policy‑driven civil fraud enforcement, potentially accelerating the development of uniform enforcement theories across districts. Taken together, these developments suggest that future FCA cases may continue to move beyond traditional billing mechanics and toward front‑end compliance representations, with heightened scrutiny of certifications made in connection with federal contracts, grants, and set‑aside programs.
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