The Department of Justice announced extraordinary results for fiscal year 2025, with False Claims Act (FCA) settlements and judgments exceeding $6.8 billion—the highest amount recovered in a single year in the statute's history. The FCA has now yielded over $85 billion in settlements and judgments since it was enhanced through Congressional amendments in 1986. These numbers underscore the critical role of whistleblowers and the government's ongoing commitment to prosecuting fraud.
Of the $6.8 billion total recovery for the year, more than $5.3 billion came from qui tam cases filed by whistleblowers. When a qui tam case succeeds, the whistleblower typically receives between 15% and 30% of the amount recovered, recognizing the personal and professional risks they take when reporting fraud.
FY 2025 also saw a record number of whistleblower cases filed, according to the government’s press release. A total of 1,297 qui tam lawsuits were initiated during the fiscal year, shattering the previous record of 980 cases set in FY 2024. This represents a 32% increase year-over-year.
Health Care Fraud Dominates Enforcement
Of the $6.8 billion in total FCA recoveries in FY 2025, health care fraud accounted for roughly 84% or $5.7 billion in total recoveries, restoring funds to government programs like Medicare, Medicaid, and TRICARE. The DOJ emphasized its recoveries in three areas:
Medicare Advantage organizations faced significant enforcement for risk adjustment fraud, which generally involves claiming or retaining payments for invalid chronic condition diagnosis codes that make patients appear sicker than they are, thereby inflating government payments.
We are proud to share that DOJ highlighted a significant Medicare Advantage case against Independent Health in which Whistleblower Partners LLP represented the successful whistleblower Teresa Ross. Independent Health agreed to pay up to $98 million to resolve the matter in December 2024. In addition to the health insurance plan, DOJ also settled with Betsy Gaffney, the CEO and Founder of DxID, a now defunct coding vendor that spun off Independent Health and is alleged to have to helped Independent Health retrospectively search medical records and query physicians for information to add improper diagnoses for Medicare enrollees. Our client courageously came forward with evidence of risk adjustment fraud, demonstrating the vital role insider whistleblowers play in protecting Medicare programs.
Another major risk adjustment settlement resolved allegations of improper spinal condition coding for over $62 million. Seoul Medical Group Inc. and its subsidiary, former president, and owner agreed to the resolution in March 2025.
An emerging space to watch is kickback enforcement in Medicare Advantage. The Department highlighted its May 2025 intervention in a whistleblower case against major insurers Aetna, Elevance Health (formerly Anthem), and Humana, along with insurance brokers eHealth, GoHealth, and SelectQuote. The case alleges the insurers paid kickbacks disguised as "marketing" payments to brokers between 2016 and 2021, causing brokers to steer Medicare beneficiaries to plans based on compensation instead of suitability for the patient. The complaint also alleges that Aetna and Humana pressured brokers to discriminate against disabled beneficiaries, who were perceived as less profitable. This case illustrates that Medicare Advantage is susceptible to schemes that go beyond risk adjustment and signals intensified scrutiny of the entire Medicare Advantage ecosystem.
Early signs suggest that FY 2026 may be another banner year for False Claims Act enforcement in Medicare Advantage. Just last week, the government announced that Kaiser Permanente affiliates agreed to pay $556 million to resolve allegations initially brought by two whistleblowers regarding risk adjustment fraud. Whistleblower Partners LLP represented Dr. James Taylor, one of the two whistleblowers in that matter.
Pharmaceutical manufacturers faced major enforcement actions in FY 2025. Several noteworthy examples include:
The opioid crisis also continued to generate significant FCA enforcement. Walgreens agreed to pay up to $350 million to settle allegations of filling invalid prescriptions for opioids and other controlled substances despite numerous red flags. These cases often benefit from whistleblowers with pharmacy expertise to identify suspicious prescribing and dispensing practices.
The DOJ pursued providers who allegedly billed for services that were not medically necessary or appropriate and for delivering substandard care. Specialty wound care provider group Vohra Wound Physicians Management LLC and its founder agreed to pay $45 million to resolve allegations of overbilling and medically unnecessary wound care procedures. Whistleblowers with clinical expertise are often helpful in uncovering these schemes, as they can recognize when billing or care doesn't align with the patient’s medical needs.
Other Noteworthy Enforcement Areas
Cybersecurity
The DOJ's cybersecurity enforcement gained momentum in FY 2025, with contractors facing scrutiny for misrepresenting cybersecurity compliance. One company agreed to pay over $11.2 million for allegedly falsely certifying compliance with cybersecurity requirements in a contract with the Defense Department.
COVID-19 Relief Program Fraud
The DOJ continues to go after fraud in relief programs. The Department highlighted a range of enforcement actions in this area, including false claims in Paycheck Projection Program (PPP) loan applications and COVID-19 testing frauds.
Trade Fraud and Customs Evasion
The DOJ continued to pursue importers for avoiding customs and other duties. It spotlighted several settlements, including an $8.1 million agreement with a wood flooring importer for alleged customs evasion, with the whistleblower receiving over $1.2 million.
Takeaways for Potential Whistleblowers
Government Enforcement is Active
With these FY 2025 figures, DOJ demonstrated its commitment to aggressively pursuing fraud. Strong whistleblower cases with solid evidence significantly increase the likelihood of government intervention and successful prosecution.
Whistleblowers are Crucial
The numbers show that whistleblowers remain key for exposing hard to detect schemes. With over $5.3 billion recovered in qui tam cases and whistleblowers eligible for 15-30% of recoveries, FY 2025 saw significant returns stemming from qui tam suits and substantial financial reward potential for those who came forward.
Industries to Watch
Based on FY 2025 trends, workers in these sectors should be particularly attuned to potential FCA violations:
Contact Experienced Qui Tam Counsel
The attorneys at Whistleblower Partners LLP have extensive experience representing whistleblowers in False Claims Act cases spanning many industries.
If you have information about fraud against the government and are considering blowing the whistle, contact us for a confidential consultation. Our team can evaluate your information, explain the process, and help you understand your options.
FY 2025’s record-breaking results—including our client’s success in the Independent Health case—demonstrate that whistleblowers make a real difference in protecting taxpayer dollars and ensuring government programs serve their intended purposes.
