COVID Stimulus and the False Claims Act: it’s not just PPP

The COVID-19 pandemic threw the US into intense economic turmoil. Businesses were closed for public health on a scale never seen before- to keep the economy from collapse, the federal government successfully deployed trillions of dollars of stimulus.

The lion’s share of economic stimulus came through the Paycheck Protection Program (“PPP”), which injected nearly a trillion dollars into the economy with the goal of keeping employees on payrolls. But a recent settlement with Delta Airlines highlights that PPP was just one of several stimulus programs, all of which are subject to enforcement under the False Claims Act.

The goal of the stimulus programs was to get money out the door to stabilize the economy. Stimulus money was generally simple to acquire and quickly distributed. That did not mean that the government didn’t have rules to participate in the program, and the Department of Justice, along with whistleblowers, have been vigorously working to recoup this money.

Indeed, there have been dozens of settlements recouping PPP money, with allegations covering everything from businesses being larger than represented, playing games with concealing related corporations when applying for PPP, and improperly disguising foreign ownership, amongst many, many other schemes.

While other stimulus programs have gotten less attention (and distributed less money) than PPP, it’s worth knowing that the False Claims Act applies to each of them, including:

  • The Payroll Support Program distributed over $25 billion of stimulus to various airlines and related entities. In July 2025, Delta Airlines agreed to pay $8.1 million to resolve allegations that it did not follow the program’s rules with regard to executive and corporate officer compensation.
  • Economic Injury Disaster Loans distributed about $300 billion to fund working capital (as opposed to paychecks) of certain small businesses and non-profits. In February 2025, the president of a Pennsylvania consulting company agreed to pay $3.2 million to resolve allegations that they misused EIDL funds by putting them into a personal investment account.
  • The Restaurant Revitalization Fund distributed about $30 billion to restaurants, bars, and other similar businesses that were forced to close due to lockdowns. In November 2023, a restaurant agreed to pay $2 million to resolve allegations that it had too many locations to qualify for the program.
  • The Shuttered Venues Operators Grants distributed about $16 billion to theatres and other arts programs that were unable to open or otherwise affected by COVID lockdowns.
  • The Provider Relief Fund distributed about $180 billion to healthcare providers who experienced revenue loss as a result of COVID (e.g., due to cancelled elective surgeries). Healthcare providers have faced allegations that they did not meet eligibility criteria.
  • The Coronavirus Food Assistant Program distributed about $24 billion to farmers to provide support to offset lost revenue from commodity sales in agriculture. In March 2023, Idaho farmers agreed to pay $500,000 to resolve allegations that they defrauded the program by improperly reporting who millions of pounds of potatoes belonged to.

Because all of these programs involved federal money, they are all subject to the False Claims Act. Whistleblowers can bring cases alleging falsehoods about eligibility or utilization requirements under any of these programs and stand to receive 15-30% of whatever the government collects.

The attorneys at Whistleblower Partners have extensive experience representing whistleblowers in cases involving COVID fraud. If you would like more information or wish to speak to an attorney at Whistleblower Partners, please contact us for a confidential consultation.