FY 2025 FCA Settlements and Judgments Statistics Show Highest Recoveries Ever

Last week, DOJ released its annual report detailing FCA recoveries and new cases, which can be found here.  In the press release, accessible here, DOJ touts two records in fiscal year 2025 (“FY 2025”): (1) $6.89 billion in settlements and judgments (a 120% increase from FY 2024); and (2) 1,297 qui tam cases filed (a 32% increase from FY 2024).  FCA cases against the healthcare industry once again accounted for a significant portion (83%) of total recoveries.

• In the fact sheet accompanying the announcement, accessible here, DOJ reviewed its priority enforcement areas and related key judgments and settlements.
  • Healthcare. DOJ highlighted settlements and judgments related to Medicare Advantage, prescription drugs, and medically unnecessary care.  These areas of focus align with the areas of focus identified when DOJ renewed the DOJ-HHS FCA Working Group in the summer of 2025, as discussed in further detail here.  We expect the efforts of that Group to result in continued robust FCA enforcement focused on the healthcare industry in FY 2026.
  • Tariff and Customs. DOJ also highlighted settlements and judgments related to tariff and customs avoidance, including a $54.4 million settlement related to a failure to pay duties on products imported from China, which is the largest customs fraud FCA settlement ever.  As we previewed here, tariff and customs enforcement is a high priority for DOJ’s Civil and Criminal Divisions.
  • Cybersecurity, Pandemic Fraud, and Defense Contracting. In addition, DOJ highlighted settlements and judgments related to more recent areas of FCA scrutiny related to alleged cybersecurity issues and fraud in connection with pandemic relief funds, as well as military procurement fraud.
• Highest recoveries ever from the healthcare industry. In FY 2025, FCA recoveries against the healthcare industry increased sharply, from $1.8 billion in FY 2024 to $5.7 billion in FY 2025.  That is the largest total ever.  The increase appears to have been driven both by outsize judgments, including jury verdicts of ~$1.6 billion and ~$950 million, and the increase in new FCA cases that has been building since 2022.

• Greater recoveries from qui tam actions where DOJ intervened, but the gap narrowed. Across industries, qui tam matters in which DOJ intervened still accounted for greater recoveries (about $3 billion) compared to qui tam matters where DOJ declined to intervene (about $2.29 billion).  However, the $2.29 billion recovered in non-intervened qui tam matters was the most ever, and almost 100% of those recoveries came from non-intervened qui tam matters against the healthcare industry.
• Whistleblowers continued to drive overall FCA activity, but DOJ continues to increase its affirmative enforcement, particularly targeting the healthcare industry. Whistleblowers filed almost 1,300 new FCA cases in 2025, representing 76% of all pending actions.  But DOJ continues its recent run of bringing more affirmative actions.  Notably, FCA matters against the healthcare industry initiated by DOJ more than doubled—from 87 in FY 2024 to 183 in FY 2025.

This post is as of the posting date stated above. Sidley Austin LLP assumes no duty to update this post or post about any subsequent developments having a bearing on this post.