Individual employees helped the government secure another successful year in False Claims Act (FCA) litigation, as both plaintiffs (whistleblowers) and individual defendants. The government collected more than $2.9 billion in FCA settlements and judgments. Of that, over $2.4 billion arose from qui tam suits. Over 970 qui tam suits were filed in 2024 — the highest number in a single year — and the government paid out over $400 million to individual whistleblower plaintiffs. In addition, the government continued to emphasize its effort to hold individual employees accountable for FCA violations in 2024, resulting in individuals, particularly senior executives and doctors, paying out millions of dollars in penalties as part of settlements with the government. The DOJ also made an effort to incentivize and reward companies that self-disclose misconduct, cooperate with investigations, and take remedial measures. Many settlements in 2024 reflected credits afforded to defendants for such cooperative measures. All of these are issues that employers and employees should be aware of when conducting business in 2025.

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: 2024 Year in Review, our 13^th annual review of significant FCA cases, developments and trends.