Historic False Claims Act Enforcement Illustrates Trump Administration’s Focus on Healthcare Fraud

False Claims Act enforcement reached yet another record high in 2025.  On January 16, 2026, the U.S. Department of Justice (“DOJ”) announced that settlements and judgments under the False Claims Act (“FCA”) reached a record-breaking $6.8 billion in Fiscal Year 2025. This is more than twice the amount of FCA settlements and judgments in FY 2024, around $2.9 billion. Relators brought 1,297 qui tam lawsuits in FY 2025, also an all-time high and a big increase over FY 2024’s 979 qui tams.

DOJ’s record year was driven largely by a focus on healthcare matters. Over $5.7 billion of the $6.8 billion in recoveries involved the healthcare industry. And unlike past record years where one or two major pharmaceutical settlements made up the bulk of the healthcare dollar figure, FY 2025 featured several healthcare FCA matters that went to trial, some of which led to large judgments for the government and relators.

The FY 2025 Fact Sheet demonstrates that DOJ has focused on healthcare cases involving managed care, prescription drugs, and medically unnecessary care. In managed care, DOJ primarily pursued matters involving the alleged use of unsupported diagnosis codes in Medicare Advantage. DOJ is also pursuing Medicare Advantage insurers and brokers for alleged kickbacks and patient steering. With regard to prescription drugs, DOJ focused on cases involving alleged illegal kickbacks in many forms, drug price reporting, and inappropriate prescribing of opioids. Finally, DOJ pursued a range of medical necessity cases, with a noted focus on wound care services.

DOJ’s focus on healthcare is consistent with the Trump Administration’s continued emphasis on healthcare fraud enforcement through cross-division and cross-agency coordination. As we previously noted in a client alert, most recently, on January 8, 2026, the White House announced the creation of a new National Fraud Enforcement Division within DOJ. This move is rare, given that DOJ is statutorily limited to eleven divisions, and reflects the Trump Administration’s commitment to fraud enforcement. Because healthcare makes up a significant portion of the government’s anti-fraud efforts, the creation of this division is another signal that healthcare fraud enforcement will remain a high priority for the government in 2026.

The government has also made cross-agency efforts to increase its focus on healthcare fraud enforcement. As detailed in a previous client alert, DOJ and the Department of Health and Human Services (HHS) announced a DOJ-HHS False Claims Act Working Group in July 2025. The Working Group, which was unveiled after months of the Trump Administration continuing to emphasize its intention to pursue healthcare fraud enforcement, announced Medicare Advantage and drug pricing among its initial priority areas.

Aside from reinforcing the government’s stated focus on healthcare fraud enforcement, DOJ’s FY 2025 FCA announcement underscored DOJ’s commitment to incentivizing cooperation and self-disclosure. DOJ entered multiple settlements in FY 2025 that credited entities and individuals, in the form of reduced penalties or damages multipliers, for self-disclosing misconduct, cooperating with government investigations, and taking effective remedial measures. This emphasis on self-disclosure has continued into 2026.  In a recent settlement that DOJ announced with Traditions Health LLC, Deputy Assistant Attorney General Brenna E. Jenny stated that healthcare entities that do not comply with Medicare rules “can mitigate the consequences by making timely self-disclosures, cooperating with the government’s investigation, and promptly taking appropriate remedial measures.” DOJ cited the company’s detailed self-disclosure; cooperation with the government; and prompt remedial actions, including removing involved individuals, improving its compliance program, and providing further employee training. In light of DOJ’s continued emphasis on disclosure and cooperation, companies should consult with counsel to carefully consider whether self-disclosure may be warranted in their circumstances.

In the coming year, healthcare and life sciences companies should expect to see continued focus on the healthcare industry and cross-division and cross-agency collaboration in the government’s pursuit of healthcare fraud matters.

Goodwin’s Government Investigations, Enforcement & White Collar Defense lawyers will continue to monitor FCA enforcement developments and their potential impact on healthcare and life sciences companies. For additional information about Goodwin’s drug pricing regulatory expertise, please visit the Goodwin Center for Market Access and Pricing. Please contact the Goodwin team with any questions related to the False Claims Act or other information in this client alert.