2025 served as a watermark year for the False Claims Act (FCA) as recoveries reached their highest total ever – over $6.8 billion – confirming the continued use of the FCA as one of the government’s most impactful tools in policing government programs. Although 2025 saw more FCA cases filed than ever before, and the government pursued new areas of focus such as customs enforcement and DEI initiatives, previous years’ trends continued in the case law. The healthcare industry remained the most targeted industry for FCA actions, accounting for nearly 84% of total recoveries. The government also continued to rely on Anti-Kickback Statute (AKS) violations as a premise for FCA liability causing courts to grapple with the appropriate causation standard to apply. The new trend of judges questioning the constitutionality of the FCA’s qui tam provisions also continued, with two Fifth Circuit judges weighing in to the debate and opinions expected from the Eleventh and Third circuits.

To keep you apprised of the current enforcement trends and the status of the law, Bradley’s Government Enforcement Investigations Practice Group is pleased to present the False Claims Act: 2025 Year in Review, our 14th annual review of significant FCA cases, developments, and trends.