Over 1,000 False Claims Act and whistleblower (known as qui tam) cases were resolved in FY’22, the second-highest number of FCA cases ever and a substantial increase in qui tam actions.  Although total monetary recoveries dipped to $2.2 billion, it’s clear that contractors need to take compliance seriously.  The 652 qui tam resolutions should perhaps be the biggest flag for contractors.  These are suits often filed by disgruntled current or former employees, competitors, or even someone just looking to make a fast buck.  Regardless of whether any actual monetary penalty results, contractors can spend significant time and money defending against these cases, draining resources and distracting from the conduct of regular business.  It can take years to resolve even questionable claims.  The best defense against a qui tam or False Claims Act case is good communication and following established procedures.  Anonymous employee hotlines, a policy of non-retaliation when someone point out something questionable, and consistent training on compliance and ethics are just some elements of a system that can minimize the risk of a suit being filed.  Even if problems are discovered, being able to show a company policy promoting compliance and consistent training on it can be the difference between being suspended or debarred or being able to continue as a federal business partner.  Contractors should also take note that, in addition to traditional contract and healthcare-related fraud, DOJ is focusing on using the FCA to combat new and emerging cyber threats.  One settlement has already been reached on this front with a non-compliant company.  Compliance cannot be an afterthought of a company’s federal business operations.  It needs to be “baked in” from the start.