By: Christopher Parrella, Esq., CPC, CHC, CPCO
Parrella Health Law, Boston, Ma.
A Health Care Provider Defense and Compliance Firm

The Department of Justice (DOJ) recently announced that False Claims Act (FCA) settlements and judgments exceeded $2.9 billion in the 2024 fiscal year, marking another milestone in the government’s aggressive pursuit of fraud. Notably, whistleblower (qui tam) actions hit a record high, with 979 cases filed—the most in history.

This trend underscores the increasing enforcement of healthcare fraud, opioid-related violations, pandemic relief abuse, military procurement fraud, and cybersecurity noncompliance. Organizations in these sectors must take proactive steps to mitigate compliance risks and avoid becoming the next DOJ target.

Key Takeaways from the DOJ’s FCA Report

1. Healthcare Fraud Continues to Dominate FCA Recoveries
   • Over $1.67 billion in recoveries involved the healthcare industry, including hospitals, pharmaceutical companies, pharmacies, labs, and individual providers.
   • The opioid epidemic remains a top enforcement priority, with settlements against manufacturers, pharmacies, and prescribers.
   • Medicare Advantage (Part C) fraud cases are rising, including allegations against UnitedHealth, Elevance Health (formerly Anthem), and Kaiser Permanente.
2. What This Means for Healthcare Providers:
   • Expect heightened scrutiny in billing practices, opioid prescribing, Medicare Advantage risk adjustments, and kickback schemes.
   • Providers must audit internal compliance programs, ensure accurate claims submission, and avoid financial incentives tied to referrals.
   Key Risk for Businesses:
   • Employees, contractors, or competitors may report fraudulent activity, leading to multi-million-dollar liability.
   • Companies should strengthen compliance training and establish whistleblower protection policies to detect and correct violations internally before lawsuits arise.
3. DOJ Expands Focus on Cybersecurity Noncompliance
   • The DOJ’s Civil Cyber-Fraud Initiative is targeting government contractors and grant recipients who fail to comply with cybersecurity regulations.
   • Recent cases include Guidehouse, Georgia Tech, and Insight Global, which faced penalties for failing to secure sensitive data.
   What Government Contractors Need to Know:
   • If your company holds federal contracts, ensure compliance with cybersecurity requirements under the Federal Acquisition Regulation (FAR) and Defense Federal Acquisition Regulation Supplement (DFARS).
   • Expect increased enforcement of cybersecurity breaches, especially if they impact federal agencies or critical infrastructure.
4. Government Procurement and Defense Fraud Remain a Priority
   • Companies providing goods or services to the military faced major FCA settlements, including:
     • Raytheon ($428 million) for false cost and pricing data.
     • Sikorsky ($70 million) for overcharging the U.S. Navy.
     • Austal USA ($811,259) for supplying defective military ship parts.
   What Defense Contractors Must Do:
   • Conduct rigorous internal audits of billing and pricing practices to ensure compliance with cost disclosure and procurement regulations.

The Bottom Line: Compliance Is No Longer Optional

With record-breaking whistleblower lawsuits and aggressive DOJ enforcement, businesses must take proactive steps to protect themselves from FCA violations.

Protect Your Business with Expert Legal Guidance

At Parrella Health Law, we help healthcare providers, government contractors, and businesses navigate complex FCA compliance issues. If your organization needs a compliance review, internal investigation, or defense against whistleblower claims, contact us today at 857.328.0382 or email Chris directly at cparrella@parrellahealthlaw.com.