Skilled nursing providers, long targeted by whistleblowers, could see enforcement increase as the Trump administration looks to expand its use of the False Claims Act in some non-traditional ways.
Providers should consider conducting targeted auditing and “otherwise prepare for a new enforcement environment.” That’s the ultimate takeaway from the 2025 False Claims Act Year in Review by Mayer Brown, a global la4w firm whose clients include healthcare organizations and investors.
“The False Claims Act 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,’” a group of five attorneys wrote last week.
“FY 2025 showed that the DOJ is committed to enforcing the FCA to deter fraud in traditional contexts, including by investigating and litigating claims against companies in the healthcare, life sciences and government contracting industries,” they added. “But the results also reveal the Trump Administration’s willingness to attempt to expand FCA enforcement to new areas, including trade, civil rights and immigration.”
The firm acknowledged that a trend of more than $1 billion annually in false claims recoveries largely from healthcare and life sciences defendants continued in 2025.
Recent settlements in high-visibility False Claims cases against two skilled nursing providers were highlighted in the Justice Department’s...
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