On 30 April 2026, DOJ announced a new anti-fraud initiative: the Fraud Oversight through Careful Use of Statistics (FOCUS) initiative. The FOCUS initiative is intended to strengthen DOJ’s working relationship with whistleblowers seeking to bring FCA actions.

Over the past several years, there has been an explosion of qui tam FCA lawsuits initiated by whistleblowers. As the firm noted in a prior alert, there was a record-high 980 qui tam lawsuits filed in Fiscal Year (FY) 2024, and that number was quickly dwarfed by a new record-high 1,297 qui tam lawsuits filed in FY 2025. That trend does not appear to be slowing down. DOJ’s announcement of the FOCUS initiative indicates that DOJ has already received more than 780 qui tam complaints midway through FY 2026.

“Much of this recent increase [in qui tam activity] has been driven by companies or individuals who analyze publicly available government data for potential signals of fraud (data miners).” According to DOJ, data miners have filed over 45% of all qui tam complaints since FY 2024.

This increase in qui tam activity has placed workload pressures on DOJ, given that DOJ is required to investigate any new qui tam complaint. To help alleviate some of that pressure, DOJ’s FOCUS initiative is aimed at identifying and prioritizing those data miners who have developed effective tools for detecting fraud against the government.

As part of the FOCUS initiative, DOJ will invite data miners to meet with DOJ’s Civil Fraud Section to...

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