False Claims Act Recoveries Hit Record $6.8B High

Recently released data from the U.S. Department of Justice confirms that the False Claims Act (FCA) is more active, and more effective, than ever. Settlements and judgments under the FCA in 2025 exceeded $6.8 billion, the highest single-year total in the statute’s history. Whistleblowers played a central role in these recoveries, filing a record number of qui tam lawsuits and helping the government uncover fraud that might otherwise have gone undetected.

The latest numbers underscore how the FCA’s whistleblower provisions remain one of the government’s most powerful tools for exposing fraud, particularly in the healthcare industry.

Key False Claims Act Highlights for Fiscal Year 2025

• $6.8 billion recovered through FCA settlements and judgments—the largest annual total ever.
• $5.7 billion of those recoveries involved healthcare-related fraud.
• Settlements and judgments in qui tam cases exceeded $5.3 billion, reflecting the continued importance of whistleblower-initiated actions.
• 1,297 qui tam whistleblower lawsuits were filed, setting a new all-time record.
• The Justice Department opened 401 new FCA investigations during the fiscal year.

What is the False Claims Act and How Does Qui Tam Litigation Work?

The False Claims Act allows the government to hold individuals and companies accountable when they knowingly submit false or fraudulent claims for payment to the United States, or knowingly avoid paying money owed to the government. Violations can result in treble or three-times damages and significant civil penalties.

A unique feature of the FCA is its qui tam provision allowing private individuals—known as relators—to file lawsuits on behalf of the government based on their knowledge of the fraud. These cases are initially filed under seal, giving the government time to investigate and decide whether to intervene.

When a qui tam case is successful, the whistleblower is typically entitled to 10% to 30% of the government’s recovery, depending on factors such as whether the government

intervened to take over the litigation and the quality of the information provided by the whistleblower.

Healthcare Fraud Remains the Primary Focus

As in prior years, healthcare fraud accounted for the largest share of FCA recoveries. Of the $6.8 billion total, more than $5.7 billion involved healthcare matters affecting federal programs such as Medicare, Medicaid, and TRICARE.

Common forms of healthcare fraud include:

• Billing Medicaid/Medicare for unnecessary urine, genetic, and psychological testing
• Underpaying rebates to the Medicaid program
• Provision of home health services to patients who are not homebound
• Providing kickbacks to induce Medicare/Medicaid/TRICARE patient referrals, including the use of copay subsidies and the payment of kickbacks to physicians in the form of speaker honoraria, speaker training fees, and opportunities to invest in testing labs

Importantly, FCA enforcement in healthcare cases not only recovers taxpayer funds but can also prevent patient harm by deterring unsafe or unethical practices.

Important Considerations for Potential Whistleblowers

For individuals considering blowing the whistle, the record-setting 2025 data offers several important takeaways:

• Whistleblower cases matter. Qui tam lawsuits continue to drive the majority of FCA recoveries.
• Timing and preparation are critical. FCA cases are complex and highly technical, particularly in healthcare fraud matters.
• Confidentiality and protection are built into the law. Cases are initially filed under seal, and the FCA includes anti-retaliation provisions to protect whistleblowers.
• Experienced legal counsel is essential. Successfully navigating a qui tam case requires deep knowledge of the FCA, healthcare regulations, and DOJ enforcement priorities.

How Waters Kraus Paul & Siegel Maximizes Whistleblower Recoveries

Our team routinely works alongside federal and state enforcement teams throughout all phases of FCA litigation. That sustained involvement often plays a critical role when recoveries are allocated. As a result, our whistleblower clients often receive the recoveries at the higher end of what’s permitted under the statute. When we feel our clients deserve more, we know how to advocate on their behalf and prevail.

Examples of FCA Recoveries by Waters Kraus Paul & Siegel include:

• $25M settlement with private equity owner of medical business over claims submitted to MassHealth. The whistleblower received the maximum award under both the federal and state statutes.
• $18.2M settlement with CVS Pharmacy to resolve federal and California FCA  claims.
• $2.8M FCA settlement with Walgreens related to Medicaid overbilling.
• $13.6M billing fraud recovery from Texas-based pain management clinic. The whistleblowers received a 22% share under the FCA.

How Do We Fight Fraud Against the Government? 

Seek justice on behalf of taxpayers with the help of our experienced attorneys. Our Dallas, Texas, whistleblower team has battled corporate giants for decades, aggressively fighting to hold corporations, individuals, and other entities accountable for fraud committed against the government. If you believe you have a whistleblower case, we can help.