False Claims Act Enforcement Ramps Up in 2025 

With record-breaking whistleblower filings and aggressive DOJ enforcement, healthcare compliance has never been more critical.  

The Department of Justice isn’t playing around with False Claims Act enforcement in 2025. Fresh off a record-breaking year that saw nearly $3 billion in settlements and judgments, federal prosecutors are doubling down on healthcare fraud investigations with what officials are calling “aggressive” enforcement strategies. If you’re in healthcare administration, compliance, or billing, this isn’t just another regulatory update you can file away. The numbers tell a stark story: whistleblower cases are at historic highs, settlements are getting bigger, and the government’s enforcement appetite shows no signs of slowing down.  

The Numbers Don’t Lie  

The DOJ announced in January 2025 that False Claims Act recoveries topped $2.9 billion in fiscal year 2024 – a significant jump that represents a 30% increase over the previous two years. But here’s what should really get your attention: healthcare fraud made up the largest portion of recoveries at over $1.67 billion, representing 57% of all FCA settlements. Even more telling is the surge in whistleblower activity. Fiscal year 2024 saw 979 qui tam lawsuits filed – the highest number in a single year. That’s nearly a thousand cases where insiders decided to blow the whistle on their employers, and the trend shows no signs of slowing as we move through 2025.   

Q1 2025: The Enforcement Momentum Continues  

During the first quarter of 2025, the DOJ announced numerous False Claims Act settlements and judgments, many resolving qui tam lawsuits filed by whistleblowers. These early-year settlements showcase the broad scope of frauds the government is pursuing – from traditional billing irregularities to more complex schemes involving AI-driven coding systems. One particularly notable case involved a $23 million settlement with an academic medical center to resolve claims that it violated the FCA when an automated coding system resulted in over-billing. This signals that the DOJ isn’t just focused on traditional fraud schemes but is actively investigating how new technologies might be facilitating compliance violations.  

The Whistleblower Factor: Your Biggest Risk May Be Internal  

Here’s a sobering reality: the vast majority of False Claims Act cases don’t start with government investigations. They start with employees who know where the bodies are buried. Whistleblower and DOJ cases combined resulted in 558 settlements and judgments in fiscal year 2024, and industry experts estimate that roughly 65% of cases originate from insider tips. This isn’t just about disgruntled employees looking for payouts. Many whistleblowers are compliance officers, billing specialists, and clinical staff who genuinely believe their organizations are putting patients at risk or defrauding government programs. When these insiders have detailed knowledge of internal processes, billing practices, and compliance shortcuts, they become powerful allies for federal prosecutors.   

Healthcare in the Crosshairs  

Healthcare organizations remain the primary target for False Claims Act enforcement, and for good reason. Law enforcement highlighted big-ticket settlements with major players like Rite Aid, Community Health Network, and Oak Street Health in their 2024 enforcement summary. The focus areas haven’t changed dramatically, but the enforcement intensity has. DOJ continues to pursue cases involving:  

• Medicare and Medicaid billing irregularities  

• Kickback schemes and improper referral arrangements  

• Off-label drug marketing and promotion  

• Clinical trial fraud and research misconduct  

• Telemedicine fraud and remote care billing  

What has changed is the government’s willingness to investigate newer areas of potential fraud, including AI-assisted coding, value-based care arrangements, and COVID-related program violations.   

The Technology Angle: AI and Automation Under Scrutiny  

The integration of artificial intelligence and automated systems in healthcare billing is creating new compliance challenges. The academic medical center settlement mentioned earlier isn’t an isolated incident – it’s likely the first of many cases where the DOJ examines how automated systems might be systematically generating improper claims. Healthcare organizations using AI for coding, prior authorization, or claims processing need to ensure these systems aren’t inadvertently creating compliance violations. The government’s message is clear: automation isn’t an excuse for inaccuracy, and organizations remain fully responsible for the claims they submit.   

What This Means for Your Organization  

The enforcement landscape in 2025 demands a proactive approach to compliance. Organizations that treat False Claims Act compliance as an annual training requirement or a checkbox exercise are setting themselves up for expensive lessons.  

Internal Controls Are Everything: With whistleblower cases driving the majority of investigations, your internal culture and controls are your first line of defense. Employees who see problems and believe they’ll be addressed internally are less likely to contact government attorneys. Billing Accuracy Can’t Be Outsourced: Whether you’re using internal staff, external billing companies, or automated systems, you remain responsible for claim accuracy. Regular audits, ongoing monitoring, and quick correction of identified issues aren’t just best practices – they’re survival strategies.  

Documentation Matters More Than Ever: In False Claims Act cases, the government’s ability to prove knowledge and intent often comes down to internal communications, training records, and compliance documentation. What you write in emails, how you document training, and what your policies actually say (versus what you do) can make or break a case.  

The Compliance Imperative  

DOJ officials have promised “aggressive” enforcement of the False Claims Act in 2025, and early indicators suggest they’re delivering on that promise. Organizations that hope to fly under the radar or assume they’re too small to attract attention are making dangerous assumptions. The enforcement math is simple: total recoveries under the FCA since the 1986 amendments now exceed $78 billion and have exceeded $2 billion annually for 16 consecutive years. This isn’t a temporary enforcement trend – it’s the new normal. Healthcare organizations need compliance programs that go beyond policy binders and annual training sessions. They need systems that actively monitor for problems, cultures that encourage reporting issues internally, and leadership that takes compliance seriously before the government comes knocking.   

The False Claims Act enforcement environment in 2025 isn’t just about avoiding penalties – it’s about building sustainable compliance cultures that protect organizations from internal and external threats. With whistleblower filings at record highs and DOJ resources focused on healthcare fraud, the question isn’t whether enforcement will continue to intensify. It’s whether your organization will be ready when it does. The organizations that thrive in this environment won’t be those that simply avoid getting caught. They’ll be the ones that build compliance into their operational DNA, treat accuracy as a competitive advantage, and create cultures where problems get solved internally rather than in federal courtrooms. In healthcare, trust isn’t just about patient relationships – it’s about maintaining the integrity that allows you to participate in federal programs. In 2025, that trust requires more than good intentions. It requires systematic, ongoing compliance that treats every claim as if a whistleblower is watching. Because increasingly, someone is.  

Sources  

1. U.S. Department of Justice, Office of Public Affairs. “False Claims Act Settlements and Judgments Exceed $2.9B in Fiscal Year 2024.” Press Release, January 15, 2025.  

2. Morgan Lewis & Bockius LLP. “DOJ Announces Over $2.9 Billion in False Claims Act Recoveries in Fiscal Year 2024.” Legal Alert, January 2025.  

3. Epstein Becker Green. “DOJ’s False Claims Act Recoveries Top $2.9 Billion in FY 2024, but Health Care Numbers Dip—What Could FY 2025 Hold for Health Care Enforcement?” Healthcare Law Analysis, 2025.  

4. Reuters Legal. “DOJ enforcement outlook in health care compliance for 2025.” March 18, 2025.  

5. Fierce Healthcare. “DOJ secured $1.7B from healthcare False Claims settlements, judgments in 2024.” January 17, 2025.  

6. Holland & Knight LLP. “Government Contracts Enforcement: DOJ Publishes FY 2024 False Claims Act Statistics.” Legal Insights, February 2025.  

7. National Law Review. “False Claims Act Settlements in Q1 Shows Scope of Frauds Targeted by Government as DOJ Official Promises ‘Aggressive’ Enforcement.” 2025. 8. CompliancyGroup. “2024 DOJ False Claims Act Settlements in Healthcare Recover $1.67B.” January 24, 2025.