• The U.S. Department of Justice recovered more than $6.8 billion under the False Claims Act (“FCA”) during the 2025 fiscal year, with nearly $5.7 billion recovered from matters involving healthcare fraud.
• The sheer size of healthcare-related recoveries underscores that fighting fraud against federal healthcare programs like Medicare and Medicaid continues to be a cornerstone of DOJ’s FCA enforcement agenda.
• Qui tam litigation brought by private citizens (“relators”) continues to drive FCA recoveries. Of the $6.8 billion recovered in FY 2025, approximately $5.3 billion came from relator-initiated actions.

As we recently discussed here https://www.law360.com/articles/2434703/traditional-fca-enforcement-surges-amid-shifting-priorities, DOJ announced record-high False Claims Act recoveries for FY 2025. In this alert, we dig into several of the key cases behind that record year.

On January 16, 2026, the U.S. Department of Justice (“DOJ”) announced that it recovered more than $6.8 billion from settlements and judgments under the False Claims Act (“FCA”) during the fiscal year ending September 30, 2025. This figure marks a nearly 120% increase over FY 2024 and, according to DOJ, “is the highest in a single year in the history of the False Claims Act.” DOJ also released a Fact Sheet highlighting the year’s largest FCA settlements, as well as several significant recoveries from whistleblower (qui tam) lawsuits in which DOJ had not intervened. DOJ recoveries under the FCA now exceed $85 billion since 1987.

Consistent with prior years, healthcare fraud continues to drive DOJ’s FCA enforcement recoveries. Of the $6.8 billion recovered, nearly 85%, or approximately $5.7 billion, related to fraud perpetrated against the U.S. Department of Health and Human Services (“HHS”), which oversees federal healthcare programs. The remaining 15% of FCA recoveries included approximately $600 million related to matters involving the U.S. Department of Defense (“DOD”) and $500 million across all other federal departments.

Qui tam litigation is a significant driver of FCA recoveries. Of the $6.8 billion recovered in FY 2025, approximately $5.3 billion arose from citizen-initiated actions, while $1.5 billion was recovered in DOJ-initiated actions. In comparison, in FY 2024, the federal government recovered $3.1 billion in total under the FCA, with $2.6 billion recovered from qui tam actions and $500 million from non-qui tam actions. A similar pattern is reflected in new investigations and case filings. In FY 2025, the government opened over 400 new FCA investigations, while private citizens (“relators”) filed nearly 1,300 new qui tam lawsuits. The ongoing challenges to the constitutionality of the FCA’s qui tam provisions could have significant implications on future FCA enforcement.

Healthcare Fraud Continues to Dominate FCA Enforcement

The sheer size and volume of healthcare-related fraud recoveries underscore that fighting fraud against federal healthcare programs continues to be the cornerstone of DOJ’s FCA enforcement agenda. The DOJ Fact Sheet highlighted several areas of continued focus in the healthcare space, including false claims related to Medicare Managed Care, prescription drugs, unnecessary medical services and substandard care. Given the sizable recoveries and DOJ’s public statements, companies should not expect this emphasis to change. As Deputy Attorney General Todd Blanche stated in the accompanying press release, “[s]topping rampant fraud is a top priority” and “the False Claims Act remains one of the government’s most powerful weapons against fraud,” which DOJ “will continue to aggressively deploy [] to protect taxpayer dollars and hold all fraudsters accountable.”

In May 2025, DOJ identified preventing fraud, waste and abuse in healthcare and other federal programs as its top white-collar enforcement priority. In June 2025, DOJ emphasized the point by announcing a nationwide healthcare fraud “takedown” that charged 324 defendants, including nearly 100 doctors and nurses, in connection with over $14.6 billion in alleged fraud. In July 2025, DOJ created a new DOJ/HHS False Claims Act Working Group to formalize interagency coordination and combat healthcare fraud. This working group supplements the new Health Care Fraud Data Fusion Center, which pools resources across the federal government and leverages artificial intelligence and advanced analytics platforms to detect and prevent healthcare fraud. Earlier this month, the White House announced the creation of a new National Fraud Enforcement Division within DOJ to “enforce the Federal criminal and civil laws against fraud targeting Federal government programs,” including potential enforcement under the FCA.

Key Verdicts and Settlements

DOJ has trumpeted many of its significant FCA settlements and jury verdicts in FY 2025, with individual recoveries reaching into the hundreds of millions—and in some cases billions—of dollars. The dollar value of FCA recoveries can be substantial given the FCA’s treble damages provision. In addition, organizations that violate the FCA may be barred from participating in federal government programs, a sanction that can be as costly as the penalties themselves. Some of the largest verdicts, settlements and qui tam lawsuits are described below.

Jury Verdicts

In August 2025, DOJ secured a unanimous jury verdict against Omnicare, the country’s largest long-term care pharmacy, and its parent company CVS for fraudulently dispensing drugs to elderly and disabled patients without valid prescriptions in violation of the FCA. Following a four-week trial, the jury found that CVS and Omnicare submitted over three million false claims to federal healthcare programs, including Medicare, Medicaid and TRICARE, resulting in a court judgment that imposed treble damages and penalties totaling nearly $950 million.

Settlements

There were many significant settlements under the FCA in FY 2025, including a $425 million settlement with the nation’s largest generic drug manufacturer for allegedly submitting false claims to Medicare in violation of the FCA; a $323 million settlement with a national consulting firm for providing advice to an opioid manufacturer that allegedly caused the submission of false claims for medically unnecessary opioid prescriptions; and a $176 million settlement with a large pharmaceutical manufacturer to resolve allegations that it paid kickbacks to induce providers to prescribe its drugs, resulting in the submission of false claims to federal healthcare programs.

Qui Tam Litigation

Although DOJ chose not to intervene, verdicts in two qui tam lawsuits led to massive recoveries for the government. These awards underscore the risk to companies arising not only from DOJ-initiated investigations, but also from FCA lawsuits without government intervention.

A June 2024 jury verdict in U.S. ex rel. Penelow v. Janssen Products LP resulted in a $1.6 billion treble damages award arising from allegations Janssen Products made misleading claims regarding the safety of its drugs, causing the submission of false claims to the government. Tellingly, while DOJ declined to intervene in the underlying litigation, DOJ intervened on the appeal to defend the constitutionality of the FCA’s qui tam provisions. The appellate argument is scheduled for March 20, 2026.

Additionally, in U.S. ex rel. Behnke v. CVS Caremark Corp., following a bench trial, a judge held that CVS Caremark, CVS’ pharmacy benefit manager, caused Medicare Part D plans to report false and inflated prices for generic drugs in violation of the FCA. The court then trebled the damages and awarded the plaintiff nearly $290 million. CVS has appealed the judgment to the Third Circuit, and it remains to be seen whether DOJ will intervene and participate in the appeal.

FCA Enforcement Continues to Extend Beyond Healthcare

Although most FCA settlements and judgments in FY 2025 involved healthcare fraud, a sizable number also related to fraud against other government programs, including military procurement fraud and tariff and customs enforcement. While smaller in number, companies must take these investigations seriously, as they can still result in significant financial penalties and disbarment from participation in federal programs.

Fraud Against the Department of Defense

Fraud involving the U.S. military accounted for the second-largest share of FCA recoveries in FY 2025. Several investigations into military procurement fraud resulted in substantial recoveries. For example, in October 2024, Raytheon paid $428 million to resolve allegations that it knowingly provided false pricing data when negotiating numerous government contracts with the DOD. Likewise, military suppliers L3 Technologies and Lockheed Martin Corp. agreed to pay $62 million and $29 million, respectively, to resolve allegations that they failed to disclose accurate pricing data in connection with military contracts.

Tariff and Customs Enforcement

FCA enforcement related to tariffs and customs avoidance also continued to gain momentum. In December 2025, DOJ obtained the largest customs fraud resolution ever under the FCA through its settlement with Ceratizit USA LLC, a distributor of tungsten carbide products. Ceratizit agreed to pay $55 million to settle claims that it knowingly and improperly failed to pay duties owed on its products imported from China. Other recoveries included settlements against companies that allegedly misrepresented their products’ countries of origin to avoid paying tariffs, including a $12.4 million settlement with Allied Stone Inc. and its president, Jia “Jerry” Lim, and an $8.1 million settlement with Evolution Flooring, Inc. and its owners, Mengya Lin and Jin Qian.

Nontraditional FCA Fraud

In June 2025, DOJ included nontraditional FCA enforcement among its priorities, noting that the Civil Division will “aggressively investigate and, as appropriate, pursue False Claims Act violations against recipients of federal funds that knowingly violate civil rights laws,” including by maintaining diversity, equity and inclusion (“DEI”) policies or “by participating in or allowing antisemitism.” In its annual report, DOJ did not explicitly state whether its statistics included recoveries related to FCA investigations regarding DEI policies or antisemitism. However, FCA cases often take years to investigate. For a more in-depth analysis of potential nontraditional uses of the FCA, please see our prior review.

Conclusion

This publication is for general information purposes only. It is not intended to provide, nor is it to be used as, a substitute for legal advice. In some jurisdictions it may be considered attorney advertising.