False Claims Act Recoveries 2024: A Record-Breaking Year
The U.S. Department of Justice (DOJ) recently announced a monumental achievement: recoveries under the False Claims Act (FCA) exceeded $2.9 billion during fiscal year (FY) 2024, of which over $2.4 billion was attributed to whistleblower (or “qui tam”) cases. DOJ also announced that FY 2024 included the highest ever number of new qui tam cases filed in a single year.
Whistleblowers’ Contribution to the $2.4 Billion Qui Tam Recoveries
The 2024 statistics continue a general trend of increases in the number of new qui tam cases in a single year. The 979 qui tam suits filed in FY 2024 breaks the prior record of 757 new qui tam cases that was set in FY 2013:
DOJ also reported that settlements and judgments from qui tam cases in FY 2024, though a slight decrease from the prior year, surpassed $2.4 billion:
Top Industries Contributing to FCA Settlements and Judgments
These settlements and judgments stemmed from cases involving a variety of sectors, with healthcare and defense being the most significant contributors. The healthcare sector once again topped the list for FCA recoveries. Fraudulent practices such as overbilling, kickbacks, and unnecessary medical procedures accounted for the majority of recoveries. Pharmaceutical companies, hospital systems, and Medicare Advantage providers were among the primary sources of the recoveries.
Notable False Claims Act Cases in FY 2024
The cases that contributed to the government’s success included a Phillips & Cohen case involving Humana, a healthcare insurance company that contracts with Medicare to provide Medicare Part D Prescription Drug Plans. In August 2024, Humana agreed to pay $90 million to the federal government to settle a whistleblower lawsuit. The suit alleged that Humana submitted fraudulent bids to the Centers for Medicare & Medicaid Services (CMS) for lucrative Part D contracts from 2011-2017, significantly overcharging the government. This was the first case of its kind to resolve allegations of fraud in the Part D contracting process.
DOJ’s announcement also highlighted continuing enforcement efforts, including another whistleblower lawsuit filed by Phillips & Cohen, which the government joined in March 2024. That case alleges six health systems and medical centers, and the alliance they established, defrauded the Department of Defense out of hundreds of millions of dollars intended to provide health care to military retirees by retaining payments they knew the government paid in error.
Enforcement Priorities: Healthcare, Opioids, Cybersecurity, and More
DOJ’s announcement additionally emphasized the government’s focus on other key enforcement priorities: the opioid epidemic, fraud in pandemic relief programs, and violations of cybersecurity requirements in government contracts and grants. Individuals considering becoming whistleblowers should be encouraged by the DOJ’s success and the financial incentives available under the FCA. As the over $2.4 billion recovered under the FCA’s qui tam provisions in FY 2024 shows, whistleblowers play a major role in recovering funds lost to many different kinds of government fraud.
Why Whistleblowers Are Key to Fighting Government Fraud
Phillips & Cohen is the nation’s most successful law firm representing whistleblowers. The firm’s cases have helped recover more than $13 billion in civil settlements and criminal fines. Phillips & Cohen represents whistleblowers in qui tam lawsuits as well as whistleblower claims with the reward programs of the SEC, CFTC, and IRS.
How Phillips & Cohen Supports Qui Tam Whistleblowers
If you are a whistleblower and would like to speak to an experienced whistleblower attorney, please contact us for a free, confidential review of your matter.
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