Fraud By The Numbers Fraud By The Numbers

The Squeeze on Relator Shares in a Record Recovery Year

Erica Roberts

2025 was a record year for FCA recoveries. For relator awards, not so much. Under the federal False Claims Act (FCA), a whistleblower (“relator”) who helps to successfully prosecute fraud against the government is entitled to an award between 15 to 30% of the total proceeds recovered by the government.1  For cases in which the government intervenes in an action, the award to the qui tam relator is capped at 25%, whereas non-intervened cases mandate that relators receive 25-30% of the overall recovery.2  

This seems like a large incentive for individuals to prosecute qui tam cases, especially where the total recoveries could reach several million. So how much did qui tam relators get in 2025?  

For all qui tam FCA cases settled in 2025, the government recovered over $5.3 billion in funds. DOJ reported that relators in 2025 made over $330 million in awards.3 This was a record year for FCA recoveries but not necessarily for relator shares. For example, in 2024, the government recovered less than half of the 2025 amount, $2.6 billion, but relator shares totaled $479 million. In fact, relator share awards were higher in 2023 ($486 million) and 2022 ($500 million) as well, even though the FCA recoveries were highest in 2025. Maybe relator awards that have yet to be awarded but are attributable to 2025 government recoveries on appeal could bridge this meaningful gap. However, from the numbers we have today, 2025 was a great year for government recoveries but not for relator awards.  

The highest known relators’ award in 2025 was for the relators who received $60.38 million, or 17.25%, of the $350 million settlement with Walgreens for filling unlawful opioid prescriptions and submitting false Medicare claims to the government. The average relator’s share percentage for the known settlements in 2025 was 15%, though some fortunate relators got 30%, or close to, including:  

  • An FCA Relator in the Middle District of Florida for a TRICARE kickback fraud scheme against an individual bad actor, Mihir Taneja. The Government recovery was $2 million. 
  • An FCA Relator in the District of Massachusetts for health care fraud against a Florida-based pharmacy, OHM Pharmacy Services. The Government recover was just over $1 million.   

The biggest takeaway seems to be that, regardless of venue, the relator’s share goes up when the total government recovery is lower. These three cases with the highest relator award percentage all had a government recovery of $1-6 million, whereas cases with lower relator percentages tend to have higher overall government recovery. Like the CVS Pharmacy FCA case where the overall recovery was over $18 million and the relator got 18%, or the Allied Stone FCA case where relators got 17.5% of the $12.4 million recovery. 

This makes sense, as the DOJ Relator Share Guidelines mention that the amount of the award is a factor to consider in determining whether to increase the percentage of a relator’s award or not: a relatively small FCA recovery is listed as a factor to support an increase in the relator’s share and the opposite is true when the recovery is large. Overall, there is still plenty of money for the taking for brave whistleblowers who come forward to bring False Claims Act cases on behalf of the government.  

This piece was written by Erica Roberts, an Associate at Sanford Heisler Sharp McKnight 

1 31 U.S.C. § 3730(d).  

2 However, if the court finds that the action was primarily based on disclosures outside of the relator’s information, the award could be no more than 10% of the total proceeds. 31 U.S.C. § 3730(d)(1).  

3 These reported awards do not necessarily capture all relator shares for the 2025 government recoveries as no relator share has been awarded for cases on appeal. For example, two large FCA judgments are pending on appeal, so no relator share has been awarded.