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ASAP

DOJ's False Claims Act Report for FY 2025 Shows Biggest Total Monetary Recoveries Yet, Provides Insight on FY 2026 Priorities

By Meredith Schramm-Strosser and N. Brenda Adimora

  • 2 minute read

According to the Department of Justice’s (DOJ) January 16, 2026 press release, the DOJ reported a record $6.8 billion in settlements and judgments under the False Claims Act (FCA) for the fiscal year ending September 30, 2025—the largest annual total in the statute’s history, more than doubling last year’s $2.9 billion. 

The tone and substance of the press release signal the Department’s ongoing enforcement priorities and intent. Deputy AG Blanche described the FCA as “one of the government’s most powerful weapons against fraud,” and pledged its continued aggressive use. The press release reflects the DOJ’s key areas of enforcement interest, which are consistent with prior years’ focus areas: 

  • Healthcare fraud dominated recoveries, with approximately $5.7 billion of the total $6.8 billion tied to healthcare-related matters including, but not limited to, managed care, prescription drugs, and medically unnecessary services.
  • Cybersecurity.
  • Pandemic-related programs.
  • Tariff evasion and customs fraud (“reverse” false claims actions wherein an entity or individual avoids payment of money due to the government thereby unlawfully keeping money owed to the government).

New to this year’s report, however, is the reference to the DOJ’s Civil Enforcement Priorities, which includes the January 21, 2025 Executive Order No. 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity, 90 Fed. Reg. 8633, which the administration implemented with the aim of combatting “unlawful DEI” practices. That the press release mentions these enforcement priorities in the first paragraph along with its reference to 401 new government investigations is undoubtedly intentional. 

Once again, qui tam suits filed by individual relators were responsible for the vast majority of the recoveries in FY 2025, accounting for more than $5.3 billion of the $6.8 billion recovered. Such suits are brought by private individuals on the government’s behalf against entities alleged to have committed fraud against the federal government. FY 2025 saw 1,297 qui tam lawsuits filed, the highest number ever recorded in a single year. Because many qui tams are filed by employees or contract workers, now more than ever businesses must be mindful of the threats that qui tams and the FCA’s anti-retaliation protections can pose. 

Taken together, the DOJ’s messaging and record‑breaking results confirm that the FCA remains a central, high‑priority enforcement tool, with no indication that activity will slow. Although self‑disclosure and remedial measures can mitigate risk in certain circumstances, those decisions must be weighed carefully in light of potential collateral exposure under the FCA and related statutes. 

Before engaging the government or initiating internal communications regarding a potential issue, employers should contact counsel to evaluate options, preserve privilege, and develop a response strategy tailored to their specific facts and industry.

Information contained in this publication is intended for informational purposes only and does not constitute legal advice or opinion, nor is it a substitute for the professional judgment of an attorney.

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