Last Friday, the Department of Justice (DOJ) released its annual False Claims Act report, announcing that FCA settlements and judgments had exceeded $6.8B in fiscal year 2025 (ending 9/30/25), and noting that the total is “the highest in a single year in the history of the False Claims Act.” Here is a breakdown of some of the key statistics:
Qui Tam is still King
- Over 77% of the total recovery ($5.34B) was the result of whistleblower lawsuits filed under the FCA’s qui tam provisions.
- Out of the total qui tam recovery, just over half (57%) came in cases where the DOJ “intervened” in the case. Where the DOJ declined to intervene, Relators recovered nearly $2.3B, the highest total ever for declined qui tam actions (the previous record was in 2022 at just under $1.2B).
- Qui tam Relators received a total of over $330M, which was down from nearly $480M in 2024.
- Although qui tam matters accounted for the vast majority of FCA recovery, non-qui tam matters (i.e., FCA matters brought directly by the DOJ) resulted in recoveries over $1.54B, the highest total since 2021, when it totaled over $4B.
- Whistleblowers filed a whopping 1,297 new qui tams in FY2025, which is by far the highest number of new qui tam actions ever.
It’s Still All About Healthcare
- Out of the total FCA recoveries, over 83% ($5.7B) were from businesses and individuals within the healthcare industry.
- Over 78% of healthcare-related settlements and judgments (nearly $4.5B) were the result of qui tam actions. Within that total, the recovery is split almost exactly evenly in terms of intervened ($2.22B) vs. declined ($2.27B) qui tams.
- Healthcare Relators received a total of over $262M in Relators share, which was down from the year before.
- Out of the 1,297 new qui tam actions filed, only around a third (458) were healthcare related.
Healthcare Fraud Focus Areas
In announcing the statistics, the DOJ’s press release focused on related matters and the following areas in particular: managed care, prescription drugs, and medically unnecessary care.
Managed Care
A fact sheet attached to the DOJ’s press release noted that “[a]s Medicare Part C is now the largest component of Medicare, both in terms of federal dollars spent and the number of beneficiaries impacted, the work of the Justice Department in this area is of critical importance.” The fact sheet listed several large managed care settlements, including a $98M settlement with Independent Health Association and a $60M settlement with Seoul Medical Group.
The fact sheet also noted that the DOJ was continuing to actively litigate FCA managed care matters against UnitedHealthcare, Kaiser (which has since settled for $556M), and Anthem.
Prescription Drugs
The DOJ also discussed its continued “pursuit of entities that engaged in misconduct related to drug pricing, drug dispensing, and illegal kickbacks that risk injecting improper financial motivations into the drugs prescribed to beneficiaries.” This included a $425M settlement against Teva Pharmaceuticals related to allegations that Teva violated the FCA by paying copays for Medicare beneficiaries while “steadily raising the drug’s price.” The fact sheet also included a jury verdict against CVS Omnicare for dispensing drugs “without valid prescriptions to elderly and disabled people in assisted living facilities and other residential long-term care facilities,” which resulted in a total judgment of just under $950M. Also included was a settlement with Gilead Sciences for $176M related to allegations that Gilead offered and paid “kickbacks in the form of honoraria payments, meals, and travel expenses to healthcare practitioners who spoke at or attended Gilead speaker events to induce them to prescribe certain Gilead HIV drugs.”
Unnecessary Services and Substandard Care
The DOJ also discussed cases involving healthcare providers submitting claims to federal healthcare programs “for medically unnecessary services and substandard care that puts at risk the health and safety of vulnerable patient populations.” This included a $45M settlement with Vohra Wound Physicians Management and its owner for submitting claims to Medicare “for overbilled and medically unnecessary wound care services.” The fact sheet also highlighted a $10.25M settlement with Oroville Hospital, related to allegations that the hospital “billed Medicare and Medicaid for medically unnecessary inpatient hospital admissions, billing for more expensive inpatient hospital admissions when observation status or outpatient care was appropriate.” Another example was a $3.6M settlement with American Health Foundation and three affiliated nursing homes, resolving allegations that the defendants billed Medicare and Medicaid for “grossly substandard skilled nursing services,” failed “to follow appropriate infection control protocols and did not maintain adequate staffing levels.”
Other Focus Areas
Outside of healthcare, the DOJ noted its continued “pursuit of fraud matters involving the purchase of goods and services by the government.” The press release explained that “[f]raud on the military squanders government funds, can deprive service members of critical resources and potentially put them at risk, and creates potential national security risks.” The press release also stated that the government was continuing “to advance cases holding government contractors and grantees accountable when they knowingly violate applicable cybersecurity requirements” and “to invest resources in recovering hundreds of millions of dollars lost to fraud in pandemic programs. “The press release also discussed efforts to combat “fraud that evades tariffs and customs duties.” Highlighted settlements include:
Military Procurement Fraud
- $428M settlement with Raytheon Company to resolve allegations that it “knowingly provided false cost and pricing data when negotiating with the Department of War for numerous government contracts and double billed on a weapons maintenance contract, leading to Raytheon receiving profits in excess of negotiated rates.”
- $62M settlement with L3 Technologies to resolve allegations that “it failed to disclose accurate, current and complete cost or pricing data relating to labor, material and other costs for communications equipment.”
- Nearly $30M settlement with Lockheed Martin to resolve allegations of “defective pricing on contracts for F-35 military aircraft.”
Cybersecurity Fraud
- $11.2M settlement with Centene Corporation and a subsidiary “to resolve allegations that they “falsely certified compliance with cybersecurity requirements in a contract to administer health benefits for service members and their families.”
- $9.M settlement with Illumina Inc. to resolve allegations that “it sold to federal agencies certain genomic sequencing systems with cybersecurity vulnerabilities and lacked an adequate security program and sufficient quality systems to identify and address those vulnerabilities.”
- A $1.25M settlement with Penn State University and a $875K settlement with Georgia Tech Research Corporation related to alleged failure to comply with cybersecurity requirements in certain government contracts.
Pandemic Fraud
The DOJ’s fact sheet states that during fiscal year 2025, the DOJ obtained more than 200 FCA settlements and judgments, collectively exceeding more than $230 million, resolving allegations of pandemic-related fraud. “To date,” the fact sheet states, “the Department has collected over $820 million in civil settlements and judgments relating to alleged fraud or improper payments in connection with pandemic relief programs.”
Notable settlements included an $8.1M settlement with delta Airlines to resolve allegations that Delta “awarded compensation that exceeded limits Delta agreed to as part of its participation in the Treasury Department’s Payroll Support Program.”
Tariff and Customs Avoidance
The fact sheet warns that “[t]hose who import and sell foreign-made goods in the United States must comply with all trade laws. The government relies on honest representations to levy and collect duties on imported merchandise. The Department had continued its efforts to root out and hold accountable actors that seek to evade tariffs and other duties.” Notable settlements included:
- $12.4M settlement with Allied Stone Inc. and its president resolving allegations that it attempted to misrepresent the type of goods imported from China in order to avoid antidumping and other duties.
- $8.1M settlement with Evolution Flooring and its owners, and a $6.8M settlement with Global Plastics to resolve allegations that they misrepresented their items’ country of origin to avoid duties.
The DOJ’s 2025 statistics make one thing perfectly clear: the FCA remains the most powerful civil took in the government’s fraud-fighting arsenal.
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The attorneys at Chilivis Grubman represent healthcare providers of all types and sizes in connection with government investigations and False Claims Act litigation. If you need assistance with such a matter, please contact us.