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Friday, May 1, 2026

Fiscal Year 2022 False Claims Act Settlements and Judgments Exceed $2 Billion - Policy & Medicine

In the Fiscal Year ending September 30, 2022, settlements and judgments under the False Claims Act exceeded $2.2 billion. That $2.2 billion total can be broken down into 351 settlements and judgments, the second-highest number of settlements and judgments in a single year. Using the settlements as a rear-view mirror can serve to better understand current government focuses, including fraud in pandemic relief programs and alleged violations of cybersecurity requirements in government contracts and grants.

Health Care Fraud

Of the $2.2 billion in settlements and judgments, more than $1.7 billion was in connection to matters involving the health care industry, including various drug and medical device manufacturers, durable medical equipment companies, home health and managed care providers, hospitals, pharmacies, hospice organizations, and physicians. Importantly, the $1.7 billion figure only reflects recoveries stemming from a federal loss; many cases involved recovering additional amounts for state Medicaid programs. This means that total Fiscal Year 2022 recoveries – state and federal – from the False Claims Act was in excess of $1.7 billion.

Medicaid

One of the settlements in Fiscal Year 2022 was the settlement between Mallinckrodt ARD LLC (f/k/a Questcor Pharmaceuticals) and the United States for $260 million over allegations that the company knowingly underpaid rebates to the Medicaid program by designating its H.P. Acthar Gel as a “new drug” as of 2013 instead of a...



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