We just released Episode 39 of the False Claims Act Insights podcast where I discussed recent oral arguments in the Third Circuit appeal of the Janssen Products case with Husch Blackwell’s Abe Souza. Abe explains how the trial of this declined qui tam—in which the Justice Department declined to intervene—led to a split
On March 10, 2026, the Department of Justice (DOJ) issued a new Corporate Enforcement and Voluntary Self-Disclosure Policy (“CEP”), which now governs all corporate criminal matters handled by DOJ except for antitrust violations. This new policy creates a single set of standards for voluntary self-disclosure, cooperation, and remediation across the Department.
We just released Episode 38 of the False Claims Act Insights podcast where I discussed DOJ’s dismissal process under 31 U.S.C. § 3730(c)(2)(A) with Husch Blackwell’s Tanner Cook. Tanner tells us about how DOJ substantially increased the number of qui tams that they affirmatively dismissed in 2025 and how DOJ analysis of qui tam
We just released Episode 37 of the False Claims Act Insights podcast, in which I discuss the DOJ’s announcement that it received a record number of qui tams in 2025, together with Husch Blackwell partner Cormac Connor. Cormac also shares recent statements from a senior DOJ official revealing the DOJ’s False Claims Act priorities
On January 28, 2026, Brenna Jenny, Deputy Assistant Attorney General for the Commercial Litigation Branch of the Department of Justice’s Civil Division, delivered comments to False Claims Act (“FCA”) practitioners about DOJ’s FCA statistics for the previous year and some of her office’s priorities for the years ahead. Jenny leads the DOJ attorneys that handle FCA investigations nationwide. Delivered at an American Conference Institute meeting in New York, Jenny touted DOJ’s record-breaking total of settlements and judgments exceeding $6.8 billion last year and confirmed there is more to come.
The Department of Justice (“DOJ”) recently released its 2025 statistics for federal False Claims Act cases. With settlements and judgments exceeding $6.8 billion last year, DOJ’s report shows that the False Claims Act (“FCA”) remains one of DOJ’s most potent and frequently-used investigation tools. The annual report also suggests that, after a year of change and turnover that touched virtually every corner and level at DOJ, the coming year will most certainly feature a historically high volume of FCA cases. Recipients of federal funds in the healthcare industry, federal contractors, and grant recipients should pay careful attention to every claim for payment or compliance certification submitted to any federal authority.
We just released Episode 36 of the False Claims Act Insights podcast with Husch Blackwell partner Lorinda Holloway where we discussed how the acts of employees can be held against organizations for False Claims Act purposes. Vicarious liability can be an odd fit with the False Claims Act, and courts take a few different approaches
The DOJ’s Civil Rights Fraud Initiative (CRFI), launched in May 2025, marks a significant expansion of federal scrutiny over DEI programs among recipients of federal funds. The initiative leverages the False Claims Act and encourages whistleblowers to report potential civil rights violations tied to DEI practices. Early investigations have targeted major corporations and universities, with
We just released Episode 35 of the False Claims Act Insights podcast where I discussed the growing amount of state-level False Claims Act enforcement with Husch Blackwell partners Rebecca Furdek and Todd Gee.
State FCA enforcement varies widely from state to state, but an increasing number of states are using FCA to combat different
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.