False Claims Act Violation Examples: Common Schemes

Billing Medicare or Medicaid for services never rendered, upcoding to more expensive codes, billing for unnecessary procedures, and duplicate claims are among the most common FCA violations in healthcare.

Kickbacks and Stark Law self-referral arrangements can also render related claims false when federal program money is involved.

Drug pricing manipulation, off-label marketing paid by federal programs, and recycling or re-billing returned medications have all produced FCA recoveries.

Substituting substandard materials, falsifying test results, cross-charging costs between contracts, and misrepresenting small-business status are classic defense and infrastructure fraud patterns.

Recognizing a pattern is often the first step. Insiders who see repeated conduct — not a one-time mistake — should consider whether their facts fit the FCA framework and speak with counsel promptly.