WASHINGTON—False Claims Act (FCA) recoveries for 2025 exceeded $6.8 billion, according to a recent report. The Barnes & Thornburg 2025 Healthcare Enforcement and Compliance Annual Report highlighted that the recoveries, which are funds returned to the United States government through lawsuits—mostly whistleblower-initiated qui tam actions—against individuals or companies defrauding federal programs, was the highest in a single year in the history of the FCA.
The Barnes & Thornburg 2025 Healthcare Enforcement and Compliance Annual Report provides an overview of the latest and most significant FCA developments, enforcement trends, civil and criminal actions, policy and regulatory updates and compliance best practices from the past year.
The report also highlighted that more than $5.7 billion of the recoveries encompassed health care sector entities, and 2025 also showed a record 1,297 qui tam actions filed by whistleblowers, signaling ongoing risk for providers, plans, labs, long-term care, life sciences and digital health entrants.
The report said there was a noticeable increase in cross-agency collaboration by components of the federal government to enforce the FCA in the health care industry. The Department of Justice (DOJ) also rolled out a joint working group with the Department of Health and Human Services called the False Claims Act Working Group. It also trumpeted the work of specialized health care “strike forces” made up of prosecutors and investigative agencies dedicated to identifying health care-related criminal activity. In conjunction with these cross-agency initiatives and strike forces, the report said agencies increased their use of data analytics and began integrating artificial intelligence to support earlier identification of potential compliance concerns.
According to the report, several key dynamics will shape enforcement and compliance risk in the year ahead, including:
- Prosecutors are differentiating between “paper” and operationally effective compliance programs, with resolutions increasingly tied to a program’s resources, authority and demonstrated effectiveness.
- Health and Human Services Office of Inspector General guidance signals persistent exposure under the Anti-Kickback Statute, Stark Law and other fraud and abuse authorities, along with heightened scrutiny of private equity and other investment models.
- Data privacy and cybersecurity pressures are intensifying, elevating the standards for risk management, contingency planning and real-time incident response.
- Self-disclosure policies continue to incentivize timely internal investigations, remediation and coordinated voluntary disclosures to reduce organizational liability.
"These developments offer health care organizations clearer signals about risk areas and underscore the value of maintaining strong, well-documented compliance programs," the report said.