Largest False Claims Act Cases by Industry: The Falsehood Behind the Payment

The largest False Claims Act settlements include billion-dollar civil agreements over drug marketing and mortgage lending, alongside major hospital, government-contracting and customs cases. For an insider who knows the coding system, the sales incentives or the price negotiation, the useful comparison is what the company told the government to get paid.

Each industry’s cases show a different point where false information can move public money: a diagnosis, a prescription, a product specification or an assurance that a loan qualifies for insurance.

Healthcare Dominates the Annual Total

The Justice Department reported more than $6.8 billion in federal False Claims Act settlements and judgments for fiscal 2025, including more than $5.7 billion involving health care.

Whistleblower cases accounted for more than $5.3 billion.

Healthcare’s weight becomes easier to understand when the cases are separated by how payment works. Selling a drug, admitting a hospice patient and adding a diagnosis to a health-plan submission create very different opportunities for an insider to see the problem.

Pharmaceuticals: Promotion, Prescriptions and Rebates

GlaxoSmithKline’s 2012 civil settlement was $2 billion across federal and state claims. The government alleged promotion for uses government programs did not cover, kickbacks, misleading safety representations about Avandia and Medicaid rebate underpayments. Whistleblower lawsuits helped expose the alleged promotion. The alleged falsehood reached both sides of the account: what public programs paid for drugs and what the manufacturer owed back.

Johnson & Johnson’s 2013 civil resolution was $1.72 billion. It covered allegations involving Risperdal, Invega and Natrecor promotion, and payments to physicians and Omnicare. A manufacturer’s sales activity could reach the government through prescriptions billed by somebody else.

Pfizer’s 2009 civil settlement was $1 billion across federal and state claims, resolving allegations that it promoted noncovered uses and paid kickbacks. Whistleblowers helped bring the case.

Biogen’s 2022 settlement was $900 million across federal and state claims. The whistleblower alleged that speaker, training and consulting payments induced prescriptions. The whistleblower continued after the government declined to take over, and the case reached a settlement.

Hospitals: Charges and Referrals Drive the Bill

Hospital cases reach reimbursement formulas as well as individual claims. HCA’s civil agreements included $745 million in 2000 and a separate $631 million federal civil settlement package in 2003. Whistleblowers brought claims in the investigation. The government’s allegations involved upcoding, unnecessary laboratory testing, home-health billing, false cost reports and kickbacks.

Tenet’s 2006 civil settlement was $900 million. The resolution included whistleblower lawsuits. More than $788 million concerned outlier payments. The government alleged that Tenet raised charges beyond its cost increases to generate excessive payments. The point was the relationship between charges and costs, something a hospital’s financial staff could recognize behind an otherwise ordinary bill.

Medicare Advantage: Diagnoses Become Revenue

Medicare Advantage cases follow the diagnoses used to increase health-plan payments. Kaiser Permanente’s January 2026 settlement was $556 million, resolving whistleblower cases pursued by the government. The government alleged diagnosis targets, financial incentives, additions long after patient visits and ignored warnings.

The government’s complaint quoted a coding leader trying to make the financial instruction presentable:

Source: United States ex rel. Osinek v. Kaiser Permanente, et al., government’s complaint quoting a coding leader

We do not think a payment target becomes a medical reason because someone finds better words for it. The allegation puts the internal instructions beside the diagnoses that reached the payment system. That connection is what a coding employee or clinician can explain.

Hospice and Skilled Nursing: Eligibility and Intensity

Hospice and nursing cases ask whether the patient qualified for the billed care and whether the intensity followed the patient’s needs. Chemed and Vitas agreed to a $75 million settlement in 2017 over allegations of ineligible hospice admissions and inflated care levels, with incentives to increase enrollment.

Life Care Centers of America settled whistleblower cases for $145 million in 2016. The government alleged corporate policies targeting the Ultra High rehabilitation payment category without clinical need, and stays prolonged despite therapists’ recommendations to discharge patients. A therapist’s recommendation and a corporate reimbursement target tell different stories about why care continued.

Laboratories and Devices: The Product Reaches Someone Else’s Claim

A laboratory or device manufacturer can affect reimbursement through the tests it sells or the purchasing decisions it influences. Quest Diagnostics’ 2009 civil resolution included $262 million in federal civil claims. The government alleged that inaccurate diagnostic kits caused laboratories to submit reimbursement claims and led to unnecessary treatment claims.

Olympus’s 2016 civil agreement set the combined federal and state civil principal at $306 million. The government alleged that grants, free equipment and other benefits were tied to purchasing decisions. Here the commercial relationship behind the equipment purchase mattered alongside the product itself.

Durable Medical Equipment and Telehealth: Use and Orders

Durable medical equipment cases can turn on whether rental billing follows actual use. Apria Healthcare’s 2020 settlement was $40.5 million. The government alleged continued ventilator rentals without confirming use, expensive equipment billed for functions cheaper equipment could perform, and improper copay waivers.

Telehealth can supply the orders that generate another company’s claims. In the Access DX case, the Justice Department reached civil settlements with the laboratory, its former chief executive and another individual after a whistleblower sued. The government alleged marketer kickbacks, purchased false telemedicine orders, unnecessary genetic testing and billing separately for tests that belonged together. The alleged chain ran from the marketer through the order to the laboratory bill.

Defense and Procurement: The Price Starts Before the Invoice

Defense procurement cases reach the information used to negotiate a contract and the specifications the delivered parts must meet. Boeing’s 2006 civil resolution was $565 million. The government alleged use of competitors’ proprietary information in launch procurement and recruitment of an Air Force official while that official participated in Boeing decisions.

Raytheon’s 2024 whistleblower case settlement was $428 million over allegations involving false cost and pricing disclosures. Northrop Grumman’s 2009 settlement concerned allegations that satellite transistors were unqualified or untested and that required disclosures were withheld.

Northrop’s agreement also shows why the payment terms matter. Its $325 million False Claims Act settlement coincided with an equally sized government settlement of Northrop’s separate contract claim. The government was settling an obligation in each direction.

Customs: The Money the Importer Keeps

Customs cases concern duties withheld from the government. Perfectus Aluminum’s May 2026 civil settlement was $549.5 million. The government alleged that aluminum extrusions were presented as finished pallets to avoid antidumping and countervailing duties.

The product description can change the duty bill. In the Toyo Ink whistleblower case, the government alleged that Chinese and Indian pigment finished in Japan and Mexico was declared as originating there without enough transformation to change its origin. Its 2012 settlement was $45 million.

The Congressional Research Service’s 2009 report, Qui Tam: The False Claims Act and Related Federal Statutes, explains why unpaid import duties can support a False Claims Act case even before the final duty bill is calculated.

Grants and Education: The Promise Behind the Funding

Research grants and student aid put different assurances between an institution and federal money. Duke University’s 2019 settlement was $112.5 million. The whistleblower alleged that fabricated research supported National Institutes of Health and Environmental Protection Agency grant applications and progress reports. The government did not take over the case.

The University of Phoenix’s 2009 settlement was $67.5 million. Whistleblowers alleged enrollment-based recruiter compensation that violated conditions of participation in federal student aid. In these cases, the experimental evidence and the recruiter pay plan explain the claim to funding.

Mortgages and Energy: Insurance, Quality and Royalties

Mortgage cases connect underwriting assurances to government-insured losses. Wells Fargo agreed to pay $1.2 billion in 2016 over allegations involving Federal Housing Administration insurance certifications for ineligible loans and failures to report defects.

Bank of America’s 2012 agreement had a $1 billion face amount. It required $500 million immediately and deferred the other half for qualifying loan modifications, with any unused balance payable to the United States. The payment obligation combined cash and conditional borrower relief.

Energy cases can concern what a contractor supplies or what a producer owes. Bechtel and URS settled for $125 million in 2016 over allegations involving deficient nuclear-quality materials, services and testing, and prohibited lobbying costs at Hanford.

Hilcorp San Juan’s 2024 settlement of False Claims Act and other liability was $34.6 million. The government alleged that estimated royalty volumes and prices were submitted without being identified as estimates and were not reconciled to actual amounts. The comparison that mattered was in the production and royalty accounts.

Software and Cybersecurity: What the Government Bought

The Justice Department’s fiscal 2017 announcement included a $155 million eClinicalWorks resolution. Cybersecurity cases extend the comparison to the security promised under government contracts.

The department’s fiscal 2025 fact sheet describes Health Net Federal Services and Centene’s $11.2 million settlement over allegations of false security-compliance certifications in a military health-benefits contract. The government alleged missed vulnerability scans, uncorrected flaws and ignored audit reports.

MORSECORP’s $4.6 million settlement concerned alleged failures to meet contract security requirements, including an inaccurate security-controls score that remained uncorrected after a consultant identified the problem. For an employee who saw the warning, the comparison is between the system’s actual condition and the assurance sent to the customer.

A Bankruptcy Claim, a Judgment and a Whistleblower Share

Some large figures describe a different kind of result. Purdue Pharma’s 2020 civil resolution created a $2.8 billion allowed unsecured bankruptcy claim.

Tuomey’s judgment over physician compensation and Medicare claims was $237,454,195. The 2015 settlement resolved that same judgment for $72.4 million. We see a striking gap between the judgment and the price of ending the case.

A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers. Duke’s announced whistleblower share was $33.75 million. The whistleblowers in the Kaiser cases were awarded $95 million.

The Part of the Business You Know

The common thread is the connection between an internal decision and public money. Diagnosis instructions, sales payments, pricing disclosures, test results, import declarations and royalty accounts each explain a different part of that connection. Evidence of what the company knew can sit with the person doing the work well before it appears in a payment claim.

Put Your Industry Knowledge to Work

If you know why an unsupported diagnosis stayed, a price disclosure changed or an import declaration misstated the goods, speak to our whistleblower experts about building your strongest False Claims Act case. We connect your industry knowledge to the government’s money, bring in False Claims Act whistleblower lawyers who know your industry’s billing and contracting practices, and stay beside you through the case.