False Claims Act and Qui Tam

False Claims Act and Qui Tam

Our False Claims Act team is one of the most experienced and deeply resourced in the United States and trusted by our clients to handle the highest stakes matters. We deploy a multidisciplinary bench of litigators, former U.S. Department of Justice prosecutors and trial attorneys, and regulatory lawyers to represent corporations, executives, compliance leaders, and witnesses in the most significant FCA investigations and enforcement actions nationwide.

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Investigations and litigation under the federal and state False Claims Acts (FCA) are among the most complex and high-stakes disputes faced by companies and individuals in heavily regulated industries. Financial exposure can be enormous, including treble damages, civil penalties, and the risk of reputational harm.

Successfully navigating these matters demands more than courtroom skill. It requires deep knowledge of the regulatory frameworks driving FCA risk, insight into government strategy, and the ability to act decisively at every stage. This combination of high-stakes litigation strength and industry insight underpins our FCA practice. From the earliest stages of an internal inquiry through government investigations, settlement negotiations, and trial, we deliver strategic, coordinated defense at every step.

Our team includes lawyers who have shaped FCA law as an enforcement tool and also established key precedents interpreting the qui tam provisions. Our lawyers have handled hundreds of FCA matters involving billions of dollars in claims, including cases brought by the DOJ and private qui tam relators, as well as parallel actions under state false claims, anti-kickback, and fraud-on-the-taxpayer statutes. Many matters have been high-profile or precedent-setting, shaping the law and influencing regulatory enforcement approaches.

We have successfully defended FCA matters across health care, life sciences, government contracting and defense, financial services, technology, education, energy, and other highly regulated sectors. Many of our FCA litigators are former DOJ prosecutors and trial attorneys, bringing firsthand experience and insider perspective to every client matter, whether defending a target, client, or witness.

Hogan Lovells is recognized as a Band 2 practice nationwide for FCA by Chambers USA, reflecting our deep experience, strategic capabilities, and the respect of our peers and clients. Clients praise our team as highly knowledgeable, aligned with government developments, and capable of quickly understanding business nuances to provide practical, actionable guidance in complex FCA matters.

Our capabilties at a glance

Representative experience

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Secured full dismissal of FCA claims for a leading health care company and defended a decade-old lawsuit with alleged damages exceeding $1.7 billion.
Achieved a significantly reduced settlement in a decade-long FCA whistleblower case against a health care provider involving billing and compensation practices.
Obtained DOJ declination in a multi-billion-dollar qui tam suit against a technology company and moved to dismiss the case.
Won dismissal of declined qui tam claims and resolved a multi-year FCA investigation in the health care sector without enforcement action.
Obtained DOJ declination in an FCA investigation involving a defense and aerospace manufacturer and moved to dismiss the relator’s suit.
Advising a biotechnology company in DOJ and USAO litigation alleging FCA violations related to government pricing reporting practices for its flagship drug.
Representing insurance company in connection with an investigation of Affordable Care Act signups and beneficiary subsidies.
Won dismissal of qui tam complaint against a national health insurer and its subsidiary alleging kickbacks to providers for referrals of dual-eligible Medicare and Medicaid beneficiaries for plan enrollment.
Won dismissal of a qui tam complaint filed against a national finance corporation, alleging company fraudulently obtained over $4.6 billion in loans from the Federal Financing Bank and Farmer Mac.
Successful settlement of FCA claim around research and development of solar technology under contracts with the National Renewal Energy Laboratory, the Department of Energy, and the Department of Defense (DOD).
Settled qui tam claim against major pharmaceutical companies alleging engagement in a scheme to misidentify certain “innovator” drugs as “non-innovator” to reduce Medicaid rebates owed to states.
Successful defense of leading research institutions in an FCA investigation involving multiple federal agencies and over $1 billion of federal funding.
Won dismissal of qui tam complaint brought against a state student loan authority relating to student loan subsidies. Dismissal affirmed by the United States Court of Appeals for the Fourth Circuit.
Won summary judgment for a major laboratory company in qui tam complaint alleging improper billing and marketing practices, as well as claimed violations of the federal Anti-Kickback Statute and the Stark Law.
Represented large health benefits company in responding to a government investigation precipitated by a qui tam complaint, culminating in the government’s decision not to intervene and in a relator’s dismissal.
Won nine motions for summary judgment defeating allegations in declined qui tam that a pharmaceutical manufacturer engaged in off-label promotion and Anti-Kickback Statute violations to generate drug sales.
Negotiated settlement for consumer products company around FCA violations based on alleged failure to pay Tariff Act duties. Successful settlement of an FCA claim involving DOD contracts for research and development of aircraft surveillance technologies.
Defended medical device company in an FCA qui tam case, in which a manager sought damages for alleged kickbacks to physicians.
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False Claims Act Guide 2026

This year’s annual Guide brings together perspectives across key regulatory and enforcement areas, including life sciences and health care, government contracts, trade, employment, privacy and cybersecurity, state attorneys general activity, and appellate developments. Drawing on cross-practice perspectives, the Guide helps companies understand where FCA enforcement stands and what may lie ahead for compliance, investigations, and litigation.

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