Top 10 Healthcare-Related False Claims Act Recoveries in 2025

By the Constantine Cannon Whistleblower Team

Last year was a record year for False Claims Act recoveries.  As the Department of Justice (DOJ) reported in its 2025 False Claims Act Roundup, the $6.9 billion the Government recovered in 2025 was the most for any single year under the statute.

Unsurprisingly, more than 80% of this amount (or $5.7 billion) came from matters involving healthcare-related fraud.  It has been that way for years, with healthcare cases accounting for about 70% of all False Claims Act recoveries since 1986 (roughly $60 billion out of $86 billion).  And it is reflected in our Top 10 listing of 2025 False Claims Act recoveries, with 7 healthcare cases making the list, including 5 of the top 6 spots.

Below, we have set forth our listing of last year’s Top 10 healthcare-related False Claims Act recoveries.  They closely track DOJ’s overarching healthcare fraud enforcement priorities, with most of them involving either illegal kickbacks under the Anti-Kickback Statute or medically unnecessary products or services.

Notably, whistleblowers originated all but one of these matters.  In fact, of the $6.9 billion the Government recovered under the False Claims Act last year, almost 80% of that amount ($5.3 billion) came from whistleblower-promoted actions.  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 roughly $86 billion under the statute, with roughly $61 billion of that amount flowing from whistleblower actions.

With all that said, here is our Top 10 list, with a link to our original post describing the action and resulting settlement in more detail:

• • No. 1 – Apex Medical ($310M).  On December 12, DOJ announced that wound graft company Apex Medical and its husband/wife owners Alexandra Gehrke and Jeffrey King would collectively pay $310 million for violating the False Claims Act and Anti-Kickback statute by billing Medicare, TRICARE, and CHAMPVA for medically unnecessary wound grafts for elderly and terminally ill patients and resulting from illegal kickbacks.  In addition to this payout, Gehrke and King were sentenced to 15.5 years and 14 years in prison respectively, and to pay more than a billion dollars in forfeitures and restitution.  The False Claims Act allegations originated in a whistleblower lawsuit under the qui tam provisions of the statute.  DOJ did not identify the whistleblowers or the award they would receive from the proceeds of the Government’s recovery.

• • No. 2 – Walgreens ($300M).  On April 21, DOJ — together with the Drug Enforcement Administration and Health and Human Services Inspector General — announced that Walgreens would pay at least $300 million to settle DOJ charges of violating the False Claims Act and Controlled Substances Act through its filling of improper opioid prescriptions.  According to the Government, for years Walgreens pharmacies filled millions of unlawful prescriptions for opioids and other controlled substances despite “clear red flags” that the prescriptions lacked a legitimate medical purpose, or were issued outside the usual course of professional practice.  The allegations originated in a whistleblower lawsuit filed by former Walgreens employees under the qui tam provisions of the False Claims Act.  They collectively received an award of 17.25% of the Government’s recovery.

• • No. 3 –  Gilead ($202M).  On April 29, DOJ announced that Gilead Sciences agreed to pay $202 million to settle allegations of violating the False Claims Act and Anti-Kickback Statute by paying physicians to speak at or attend sham medical conferences to induce them to prescribe various Gilead HIV drugs.  The allegations originated in a whistleblower lawsuit filed under the qui tam provisions of the False Claims Act, but DOJ did not identify the whistleblowers involved or the award they would receive.

• • No. 4 – Horizon ($100M).  On November 14, New Jersey Attorney General Matthew Platkin announced that Horizon Healthcare Services (known as Horizon Blue Cross Blue Shield of New Jersey) would pay $100 million to settle allegations of violating the New Jersey False Claims Act by overcharging the State on its contract to administer the State’s employee benefit programs.  It is New Jersey’s largest non-Medicaid False Claims Act settlement ever.  The State’s action originated from a lawsuit filed by six whistleblowers under the qui tam provisions of the New Jersey False Claims Act.  As part of the settlement, the State agreed to provide five of the whistleblowers — Kevin Lyons, Patrick Colligan, Mark Kovar, Mark Flores, and Vince Flores — a $12 million whistleblower award from the proceeds of the settlement.

• • No. 5 – Empire Pain Center ($63.8M).  On April 21, DOJ announced that two operators of New Jersey’s Empire Pain Center Holdings — Eric Karlewicz and Nicco Romoanowski — would pay $63.8 million for violating the False Claims Act and Anti-Kickback Statute by billing Medicare for medically unnecessary body braces and other durable medical equipment (DME) and exchanging kickbacks with telemedicine companies, physicians, and DME suppliers to further the scheme.  In addition, Karlewicz and Romanowski were sentenced to 51 and 80 months in prison respectively, and ordered to forfeit close to $70 million.  The matter was originated by Robert Jackson Tyler Jr., under the whistleblower provisions of the False Claims Act.  DOJ did not disclose the amount of the award.

• • No. 6 – Biohaven ($60M).  On January 24, DOJ announced Pfizer subsidiary Biohaven Pharmaceutical Holding Company would pay roughly $60 million to settle allegations of violating the False Claims Act and Anti-Kickback Statute by paying kickbacks to induce prescriptions of Biohaven’s migraine medication Nurtec.  According to the Government, Biohaven provided healthcare professionals with paid speaking opportunities and expensive meals for programs with no educational benefit.  Pfizer terminated the Nurtec speaker programs after it acquired Biohaven.  The allegations originated in a whistleblower lawsuit filed by former Biohaven sales representative Patrica Frattasio, who received a whistleblower award of $8.4 million from the proceeds of the Government’s recovery.

• • No. 7 – Seoul Medical ($58.7M). On March 26, DOJ announced that California-based Seoul Medical Group and its subsidiary Advanced Medical Management would pay $58.7 million to settle allegations they violated the False Claims Act by inflating the risk scores for their Medicare Advantage patients to inflate their Medicare reimbursement.  The allegations originated in a whistleblower lawsuit but DOJ did not identify the whistleblower or the amount of the whistleblower award.

• • No. 8 – Vohra ($45M). On November 21, DOJ announced that Dr. Ameet Vohra and his wound care company Vohra Wound Physicians Management would pay $45 million to settle allegations they violated the False Claims Act by billing Medicare for medically unnecessary surgical procedures, for procedures not performed, and for evaluation and management services Medicare does not cover.

• • No. 9 – Aesculap ($38.5M). On November 17, DOJ announced that Pennsylvania-based medical device company Aesculap Implant Systems would pay $38.5 million to settle allegations it violated the False Claims Act by selling knee replacement devices it knew would fail prematurely at a higher than acceptable rate, rendering the implants medically unreasonable and unnecessary.  The Government also claimed the company paid kickbacks to an orthopedic surgeon to induce him to use the knee implants.  The allegations originated in a whistleblower lawsuit filed by John Marien and Michael McGee, third-party distributors for Aesculap, who received a whistleblower award of $4,475,000 from the proceeds of the Government’s recovery.

• • No. 10 – Semler/Bard ($37M). On September 26, DOJ announced that Semler Scientific and its former distributor Bard Peripheral Vascular agreed to pay a combined $37 million to settle charges they violated the False Claims Act by causing healthcare providers to bill Medicare for certain uncovered medical devices.  The allegations originated in a whistleblower lawsuit filed by Robert Kane and Franklin West, who will receive a total whistleblower award of roughly $6.5 million from the settlement.

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Constantine Cannon partner Dan Vitelli found the Top 10 listing wholly consistent with DOJ’s perennial enforcement priority of going after illegal kickbacks and medically unnecessary services.  According to Vitelli, “DOJ has made it very clear it does not tolerate either area of healthcare fraud.  It has been this way for years and recent enforcement actions demonstrate that the government is continuing to take that approach.”

Vitelli further noted the critical role whistleblowers play in supporting DOJ in this effort.  “It’s not surprising that whistleblowers initiated 9 of the Top 10 False Claims Act cases involving healthcare fraud last year,” he said.  “The whistleblower provisions of the statute are a key reason why the False Claims Act has been so successful over the years. Without whistleblowers coming forward and reporting inside information, many of these schemes would never be uncovered.”

Constantine Cannon has substantial experience representing whistleblowers under the False Claims Act.  If you would like to learn about our various whistleblower successes or what it means to be a whistleblower under the False Claims Act, please do not hesitate to contact us.  We will connect you with an experienced member of our whistleblower team for a free and confidential consultation.  Maybe you will be responsible for exposing the next big healthcare fraud case!

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