The year 2021 marks the 10th anniversary of the Bradley False Claims Act Year in Review. In that decade, much has remained the same in FCA enforcement. To start with the obvious: It continues to result in billions of dollars in recoveries to the United States at the expense of FCA defendants. Over the years, we’ve described that enforcement as “robust,” “significant,” and “aggressive” multiple times, and this year is no different with over $5.6 billion in judgments and settlements — the second highest total ever. But FCA jurisprudence has also changed in important ways, too, as significant court decisions, Department of Justice (DOJ) policies, and evolving industry practices shape the type of cases brought and how they are resolved.

We examine those trends and much more in this year’s review. We begin this year with a brief look back at the decade since we first published the FCA Year in Review in 2012, focusing particularly on Supreme Court decisions and other large-scale developments related to the FCA.