10 Takeaways from DOJ’s Record-Setting FY2025 Civil Fraud Recoveries 

In January 2026, the U.S. Department of Justice (DOJ) released its annual report on civil fraud recoveries (settlements and judgments) for FY2025.  Bass, Berry & Sims analyzed these developments in greater depth in its 14th Annual Healthcare Fraud & Abuse Review. Our key observations from DOJ’s release include:

1. Total Recoveries Set All-Time Record.  DOJ announced nearly $6.9 billion in settlements and judgments in FY2025, eclipsing the prior record by more than $700 million and more than doubling FY2024 recoveries. The year began with momentum, including two settlements totaling more than $850 million announced late in 2024. 
2. Recoveries Paced by Rare FCA Trial Outcomes.  There were an atypical number of high-dollar judgments following relatively rare False Claims Act (FCA) trials last year, including a $948.8 million judgment against Omnicare, a $290 million judgment against CVS Caremark, and a more than $1.6 billion judgment against Janssen Pharmaceuticals.  Each of those judgments is on appeal, leaving open the possibility that FY2025’s record totals may change.
3. Healthcare Industry-Related Recoveries Reverse Downward Trend.  After several years in which annual recoveries involving the healthcare industry remained below $2 billion, last year’s recoveries involving the healthcare industry hit an all-time high of more than $5.7 billion, demonstrating the DOJ’s continued emphasis on healthcare fraud under the FCA.  And, the diversity of what constitutes “healthcare” constitutes to evolve.  It ranges from everything from allegations involving the medical necessity of skin substitute therapy to Part C risk adjustment-related payments.
4. Percentage of Total Recoveries Involving the Healthcare Industry Returned to Historic Levels.  In FY2024, FCA recoveries involving the healthcare industry amounted to only 57.3% of the total recoveries—a significant drop from the roughly 80% level at which healthcare recoveries have historically hovered.  For FY2025, recoveries involving the healthcare industry rebounded to 83%, which demonstrates that while healthcare remains a priority, the fraud “pie” itself is growing: FCA exposure now much broader and more expansive than it’s ever been.
5. Number of Newly-Filed Qui Tam Lawsuits Smashes Prior Record (Again).  An astonishing 1,297 qui tam lawsuits were filed in FY2025, surpassing the prior record of 979 filed in FY2024. Over the past five years, more than 4,200 qui tam lawsuits have been filed. 
6. Recoveries Stemming from Qui Tam Lawsuits Remain High.  The record setting year also included the highest dollar amount of recoveries ever associated with matters initiated by the filing of qui tam lawsuits ($5.34 billion), which reflected 77% of total recoveries.
7. Percentage of Qui Tam Lawsuits Involving Healthcare Industry Continues Downward Trend.   For FY2025, healthcare-related qui tam filings increased to 458 (up from 370 in FY2024). As a share of total filings, however, healthcare cases continued their downward trend, accounting for only 35% of all qui tam lawsuits—well below the five-year average of 53%.
8. Large Judgment Drives Record-Setting Recoveries in Declined Healthcare Qui Tam Matters.  A significant portion of recoveries stemmed from cases where DOJ declined to intervene, including the $1.6 billion Janssen judgment, contributing to nearly $2.3 billion in recoveries from declined matters, which shows that non-intervened cases expose companies to continued risk if left unresolved by the DOJ.  It remains to be seen if the DOJ will actually exercise its (c)(2)(A) dismissal power more often under Trump 2.0.
9. Relator Share Awards.  Although DOJ announced a record-setting year of FCA recoveries in matters arising from qui tam lawsuits, relator share awards amounted to only $330 million, well below the 10-year average of $438 million.  This disparity is likely the result of the fact that relator shares have not yet been awarded in matters where judgments totaling over $2.8 billion remain pending on appeal. 
10. Non-Qui Tam Matters.  DOJ reported more than 400 new non-qui tam matters in FY2025, consistent with totals from the past five years and the third-highest number since the 1986 FCA amendments. Many of these matters involved consent judgments and smaller recoveries tied to pandemic-related Paycheck Protection Program (PPP) claims.

 Download the full Review for a comprehensive look at the FCA and enforcement trends.