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Sunday, October 12, 2025

A False Claims Act FY 2025 Year in Review - Mayer Brown

The False Claims Act (FCA) is the government’s principal weapon against fraud. It is a broad and flexible statute that was intended to “reach all types of fraud, without qualification, which might result in financial loss to the Government.”1 Because of its breadth, it can be used in myriad ways—some traditional and others novel. With fiscal year 2025 ending last week, we look back to see how FCA enforcement is evolving to reflect the priorities of the new Trump Administration.

Health Care

FCA enforcement has traditionally focused on the health care and life sciences industries, with annual recoveries routinely exceeding $1 billion. That trend continued during FY 2025 with a number of high-dollar settlements, including two under the Medicare Advantage program, which remains an area of focus. Specifically, in December 2024, a Medicare Advantage provider agreed to pay $98 million to resolve allegations that it violated the FCA by submitting invalid diagnosis codes to inflate the “risk scores” of its patient population. Then, in March 2025, a company, its subsidiary, and its majority owner paid $62 million to settle FCA claims relating to billing for spinal conditions under the Medicare Advantage program.

DOJ has also focused on kickbacks. In January 2025, a pharmaceutical company agreed to pay nearly $60 million to resolve allegations that a subsidiary had paid kickbacks in exchange for prescriptions and caused these prescriptions to be submitted to federal health care...



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