DOJ's Annual False Claims Act Roundup For 2025 -- Another Record Year for Whistleblower-Initiated Fraud Enforcement

Posted January 21, 2026

By the Constantine Cannon Whistleblower Team

Last Friday (January 16), the Department of Justice released its Annual Report of False Claims Act enforcement for the fiscal year ending September 30, 2025.[1] By all accounts, it was another record year for fraud enforcement with the Government recovering roughly $6.9 billion, the largest single-year haul ever under the statute. As usual, the bulk of that amount — more than $5.3 billion — came from actions originated by whistleblowers under the qui tam provisions of the statute.

What Role Have Whistleblowers Played in Enforcing the False Claims Act?

This has been a repeat pattern since 1986 when the statute was significantly amended to increase the protections and financial incentives for whistleblowers to step forward. Since then, the Government has recovered more than $85 billion under the statute, with roughly $61 billion of that amount flowing from whistleblower actions.[2]

Especially notable this past year is that of the $5.3 billion in whistleblower-prompted recoveries, $2.3 billion came from False Claims Act cases whistleblowers pursued on their own. This follows from the unique nature of the statute, which allows whistleblowers to pursue litigation on behalf of the Government against fraudsters even when the Government declines to join the case. This $2.3 billion single-year figure accounts for roughly 30% of all the recoveries whistleblowers have secured in Government-declined False Claims Act cases over the past thirty years combined.

This past year was also a record year for whistleblower filings, with whistleblowers filing 1,297 qui tam lawsuits. This number far surpasses the 980 qui tam suits whistleblowers filed in 2024, which had been the prior record and which itself had far surpassed the number of qui tam suits whistleblowers had filed any year before that. The number of cases whistleblowers filed last year also was more than three times the number the Government filed (401), again reinforcing the critical role whistleblowers play in enforcing the False Claims Act.

What Primary Subject Areas Did the False Claims Act Cases Cover?

DOJ highlighted three primary areas of fraud that were the subject of last year’s False Claims Act settlements and judgments — healthcare fraud, procurement fraud, and customs fraud. DOJ has traditionally treated each of these areas as top enforcement priorities and the Trump Administration appears to be staying this enforcement course.

As it has for years, healthcare fraud was the leading source of recoveries this past year with $5.7 billion of the $6.9 billion in recoveries coming from healthcare-related matters and improper payouts from Medicare, Medicaid, and TRICARE. DOJ specifically pointed to actions involving managed care like Medicare Advantage (Part C), prescription drugs, medically unnecessary care, and protecting patients from potentially harmful conduct.

With procurement fraud, DOJ specifically called out military contractor fraud, underscoring how it not only squanders government funds, but also puts both our servicemembers and national security at risk. DOJ likewise underscored its focus on cybersecurity violations by Government contractors and grant recipients and COVID-19-related fraud.

With customs fraud, DOJ underlined its focus on those attempting to mischaracterize the quality, character, or country of origin of their imports to evade customs duties. DOJ also promoted its launch of a cross-agency Trade Fraud Task Force “to enhance efforts to prevent trade fraud that deprives the government of vital revenues, threatens critical domestic industries, undermines consumer confidence, and weakens national security.”

How Much Does DOJ Rely on Whistleblowers?

There are two messages that ring loud and clear from DOJ’s False Claims Act report. One, DOJ will continue to use the False Claims Act to aggressively pursue those committing fraud against the Government. And two, DOJ will rely on whistleblowers to lead the way.

DOJ Civil Chief Brett Shumate did not mince words in trumpeting this sentiment: “The False Claims Act and its whistleblower provisions are crucial tools for ensuring that public funds are spent properly and in the public interest.” Deputy Attorney General Todd Blanche added that “stopping rampant fraud is a top priority, and this record-breaking year proves the False Claims Act remains one of the government’s most powerful weapons against fraud.”

In further underscoring the critical role of whistleblowers, DOJ emphasized how the False Claims Act was “strengthened” with the 1986 amendments “by increasing incentives for whistleblowers to file lawsuits alleging false claims on behalf of the government.” DOJ likewise noted the “significant percentage” False Claims Act cases whistleblowers file each year, the “significant recoveries” these cases yield, the substantial whistleblower awards that flow from these recoveries, and the record number of qui tam suits whistleblowers filed this past year.

Constantine Cannon whistleblower partner Marlene Koury remarked how DOJ’s report reflects the Government’s continued recognition of the importance of whistleblowers in enforcing the False Claims Act. “DOJ seemed to go out of its way to not only highlight this past year’s record recoveries under the statute, but also to underscore the critical role whistleblowers played in securing those recoveries.” According to Koury, “There can be little question the Government wants whistleblowers to continue bringing these cases and will continue rewarding them for doing so.”

Constantine Cannon Has Substantial Experience Representing False Claims Act Whistleblowers

Constantine Cannon has substantial experience representing whistleblowers under the False Claims Act. In fact, the firm represented one of the whistleblowers who initiated the first case DOJ featured in its listing of False Claims Act successes this past year.[3] This was against Buffalo-based Independent Health for allegedly engaging in Medicare Advantage fraud by submitting invalid and unsupported diagnosis codes to Medicare. In December 2024, Independent Health agreed to pay up to $98 million to settle the matter, with the whistleblower receiving at least $8.2 million from the proceeds of the government’s recovery.

Constantine Cannon also represented one of the whistleblowers who initiated another False Claims Act case DOJ featured. This one against Oakland-based Kaiser Permanente, also for allegedly engaging in Medicare Advantage fraud by submitting invalid diagnosis codes. Just last week, Kaiser agreed to pay $556 million to settle the matter, the largest False Claims Act settlement to date involving alleged fraud on the Medicare Advantage program.

These are just two of the firm’s False Claims Act successes in this area. To learn more about these and the firm’s other successes, the False Claims Act, or what it means to be a whistleblower more broadly, please do not hesitate to contact us. We will connect you with an experienced member of the Constantine Cannon whistleblower team for a free and confidential consultation.