Enforcement Just Had Its Biggest Year Ever — Here's What Changed

Federal healthcare fraud enforcement just had its most aggressive year on record — and the infrastructure behind it suggests 2026 won’t slow down.

In January, the Department of Justice announced that False Claims Act settlements and judgments for fiscal year 2025 topped $6.8 billion, the highest annual total since the statute was substantially strengthened in 1986. More than $5.7 billion of that came from healthcare matters. Whistleblowers filed 1,297 qui tam lawsuits over the same period — also a record — and the government opened 401 new investigations.

The number that should get a compliance program’s attention isn’t the total, though. It’s the infrastructure. DOJ has stood up a new National Fraud Enforcement Division specifically to sustain this pace, and 2026’s enforcement actions show a clear pattern: civil, criminal, and administrative tools are increasingly being deployed together on the same matter, rather than sequentially. A provider under FCA scrutiny is now more likely to be facing parallel exposure — civil recovery, potential criminal referral, and program exclusion risk — developing simultaneously rather than one after another.

That convergence is exactly why treating the False Claims Act, the Anti-Kickback Statute, and Stark Law as three separate compliance checkboxes is a losing strategy. The government isn’t investigating them separately anymore, and a program that only assesses AKS risk in isolation from FCA exposure is missing how these cases actually get built. An arrangement that raises a Stark Law technical violation doesn’t just sit there — it becomes the predicate for an FCA claim the moment a claim gets submitted referencing that arrangement. That’s not a theoretical connection. It’s the fact pattern behind a large share of this year’s largest settlements.

This is the exact intersection Volume 2: Core Legal & Regulatory Framework is built around — not summarizing each statute in isolation, but walking through where they overlap, where one triggers exposure under another, and what that means for how a compliance program should actually be structured to catch it. If your program’s risk assessment still treats these as three separate line items, this is worth a closer look before your next audit cycle.

Volume 2 is available now as part of the Healthcare Compliance & Quality Compendium.