On January 16, 2026, the Department of Justice (DOJ) announced record-breaking recoveries of more than $6.8 billion under the False Claims Act during fiscal year 2025 (covering October 1, 2024 through September 28, 2025). While some of these recoveries occurred prior to the new administration or resulted from declined qui tam cases, DOJ’s announcement nevertheless highlights its continuing commitment to False Claims Act enforcement, with an emphasis on healthcare, cyber, and customs fraud.
As in prior years, the overwhelming majority of the government's recoveries occurred in health care cases. DOJ reported more than $5.7 billion in settlements and judgements in various health care matters, including cases involving Medicare Part C, prescription drugs, or medically unnecessary or substandard services. Outside of the healthcare arena, DOJ reported recovering more than $600 million in cases related to the Department of Defense (now the Department of War). Total recoveries under the False Claims Act since 1986, when the statute was substantially amended, now exceed $85 billion.
Of the $6.8 billion recovered during fiscal year 2025, more than $1.3 billion was reported in cases settled during the Biden administration and another $1.3 billion was reported in cases filed during the Biden administration. In addition, more than $2.2 billion was recovered in cases pursued by relators after the government declined to intervene in those matters.
Other notable aspects of the government’s fiscal year 2025 False Claims Act enforcement efforts announced by the government include:
- Nearly 60% of the total reported recoveries were accounted for by just six cases. Two of these six cases were settled within approximately two weeks of the close of the prior fiscal year. The judgments entered in another three of the six matters, totaling in excess of $2.8 billion, are pending on appeal.
- DOJ reported the filing of a record-breaking 1,297 new qui tam actions in fiscal year 2025. Nearly two thirds of these new qui tam cases were reported in the “other” category in DOJ’s stats sheet – meaning they were neither health care nor defense related. This is only the second time – the other time being in fiscal year 2024 – that health care fraud did not constitute the primary source of qui tam cases in the last 30 years. Although the number of health care qui tam cases as a percentage of total cases was significantly lower in fiscal year 2025, the number of health care qui tam cases in absolute terms – 458 – was nevertheless at its highest level in the last five years.
- DOJ opened 401 new matters in fiscal year 2025 based on sources of information other than qui tam cases. This is the third highest number of government-initiated matters since 1986.
- DOJ recovered more than $230 million in more than 200 pandemic fraud settlements, and more than $52 million in cybersecurity fraud settlements, which is triple the amount recovered in cybersecurity related cases in fiscal year 2024.
- DOJ highlighted tariff and customs avoidance as a focus of the government’s False Claims Act enforcement efforts, including a record $54 million settlement with an importer of Chinese goods that was finalized after the close of fiscal year 2025.
- Unlike in recent years, the Department did not identify the total number of recoveries that it obtained in fiscal year 2025. The Department reported a record number of 566 settlements and judgments in fiscal year 2023, and almost an equal number of settlements and judgments in fiscal year 2024.
The recoveries reported by DOJ suggest that we can expect continued False Claims Act enforcement across a range of government programs and operations, with a focus, in particular, on healthcare, cyber, and customs matters.
If you have any questions concerning the material discussed in this client alert, please contact members of the False Claims Act practice.
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