Compliance Stuff

2025 has been a landmark year for False Claims Act (FCA) enforcement, marked by record-breaking settlements, evolving legal theories, and a broadening scope of government priorities. The FCA remains one of the federal government’s most potent tools for combating fraud, with billions recovered annually and an ever-expanding reach into new sectors and compliance areas . This roundup synthesizes the year’s most significant developments—drawing on recent case law and shifting enforcement priorities—and provides actionable insights for businesses navigating the FCA landscape. Case Law Update: Constitutional Challenges and Qui Tam Relators In 2025, the constitutionality of the FCA’s qui tam provisions—which empower private litigants (relators) to prosecute fraud claims on the government’s behalf—continued to emerge as a focal point of judicial debate . Historically, federal courts, including the U.S. Court of Appeals for the Fifth, Sixth, Ninth, and Tenth Circuits, have rejected arguments ch...

  The government has announced a renewed and expanded focus on False Claims Act ( FCA ) enforcement, doubling down on traditional health care priorities like kickbacks and drug pricing while signaling increased scrutiny of Electronic Health Records ( EHR ) manipulation, a shift that could expose data vendors and other non-traditional health care entities to the  US  Department of Justice ( DOJ ) and the  US  Department of Health and Human Services ( HHS ) scrutiny. Read the announcement  here . Leveraging enhanced cross-agency collaboration and sophisticated data mining, federal agencies are poised to generate new investigative leads, building on recent DOJ enforcement successes. Key Points of Emphasis and Related Compliance Takeaways The revived DOJ-HHS FCA Working Group signals that aggressive, coordinated health care enforcement is not only continuing but expanding into data-driven and technology-enabled frontiers. Reinvigorated False Claims Act Wor...