Record-Breaking Qui Tam Filings: A Wake-Up Call for Healthcare Compliance

The Surge We Can’t Ignore

The inspiration for this blog came from the DOJ Trendlines report recently released by the Anti-Fraud Coalition¹. The headline? In 2024, whistleblowers filed 979 qui tam lawsuits under the False Claims Act (FCA)—the most ever recorded in a single year. That number didn’t just edge out the previous high of 752 in 2013—it blew past it.

For healthcare compliance professionals, this milestone isn’t just a data point. It’s a message. A wake-up call.

As someone who’s spent years in the trenches of healthcare compliance, I’ve seen patterns before, but this is different. The Department of Justice (DOJ) is clearly signaling a redoubling of efforts to combat fraud, and the public—particularly insiders—is stepping up to help. Or, depending on your viewpoint, stepping in where compliance has failed.

The Healthcare Sector: Always in the Crosshairs

Historically, the healthcare industry accounts for the majority of FCA recoveries—and 2024 was no exception². Whether it’s Medicare Advantage coding manipulation, improper kickbacks, or upcoding for services not rendered, health providers remain one of the DOJ’s most profitable and visible targets.

Qui tam suits aren’t random. They often come from staff who raised concerns internally and felt unheard. That means what appears to be a federal enforcement issue is often a breakdown in internal compliance culture.

Whistleblowers Are Watching—and Acting

Why the spike now? A few possibilities:

• Increased awareness: Organizations like the Anti-Fraud Coalition (TAF) and government campaigns have amplified the public's knowledge of whistleblower rights and rewards.

  
  

• Greater incentives: Whistleblowers can receive 15% to 30% of any recovery stemming from their lawsuits³.

  
  

• Workforce frustration: Employees today have higher expectations for ethical leadership—and less tolerance when it’s missing.

The takeaway? Every compliance team should view internal whistleblower protections as frontline defense. If you don’t create trust within, someone may take their evidence to the DOJ instead.

What Should We Be Doing?

1. Evaluate Your Internal Reporting Systems

   Is your compliance hotline functional, anonymous, and trusted? If not, your organization is exposed.

   
   

2. Recommit to Training

   Annual check-the-box compliance training won’t cut it anymore. You need tailored, interactive education that makes the stakes—and protections—clear to all employees.

   
   

3. Audit More, Not Less

   Regular internal audits aren’t a luxury; they’re an essential risk management tool. Focus especially on high-risk billing practices and third-party vendor relationships.

   
   

4. Act Fast and Document Well

   When a concern is raised, investigate quickly. If there’s wrongdoing, take corrective action—and document every step. This record can be your best defense if a whistleblower complaint becomes federal interest.

A Final Word

The DOJ Trendlines report makes it clear: 979 qui tam cases in one year isn’t just a statistic—it’s a directional signal¹. The DOJ has the tools, the whistleblowers have the motivation, and the compliance gaps are where it all begins.

Want help strengthening your internal reporting systems, auditing practices, or overall compliance culture?

Simply Compliance partners with healthcare organizations to turn whistleblower risks into opportunities for improvement. From internal assessments to policy development and workforce training—we can help you get ahead of the next headline.

Get in touch with Jessica Zeff @ Simply Compliance.

Endnotes

1. The Anti-Fraud Coalition. “DOJ Trendlines: A Look at the Numbers.” Published September 4, 2025. https://www.taf.org/doj-trendlines 

2. U.S. Department of Justice. “Justice Department Recovers Over $2.68 Billion from False Claims Act Cases in Fiscal Year 2023.” Press Release, February 22, 2024.

3. 31 U.S. Code § 3730(d). False Claims Act whistleblower reward provisions.