While FY 2025 was a unique and record-setting year for FCA cases in many respects, it also affirmed that many of our long-standing conclusions about the use of the FCA in health care cases remain true. Settlements and judgments in health care cases continue to represent the majority of FCA resolution dollars even though such cases do not represent the majority of FCA cases overall
New Cases in 2025 Soar Past 2024's Record Highs
Recoveries Approach $7 Billion,with Health Care Cases Leading the Way
In Mintz's annual report on False Claims Act case activity, we examine health care enforcement trends, predict how health care enforcement may evolve, and offer practical guidance about what these trends and predictions mean for health care providers, payors, and other stakeholders.
A four-year surge in False Claims Act (FCA) case activity roared on unabated during the federal fiscal year (FY) that ended September 30, 2025. As the Department of Justice (DOJ) reported in itsannual statistical report, 1,698 new FCA cases were initiated in FY 2025. This number exceeds by 21% the previously record-setting number of FCA cases recorded in FY 2024 (1,405).
Despite the significant increase in overall cases initiated, the number of cases initiated by the government (401) — including pre-suit investigations by DOJ and agency
inspectors general — fell slightly from FY 2024 (425). The primary driver of the overall growth in FCA cases was a 32% increase in qui tam cases filed under the FCA's...
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