On Tuesday, President Donald Trump announced the Fraud Whistleblower Incentive Program (WHIP), designed to reward whistleblowers whose tips on certain types of fraud lead to criminal charges. The program differs from existing federal whistleblower reward programs in several meaningful ways – notably in the quicker but much smaller awards it offers – and a number of program details remain unclear.
According to a Justice Department press release, WHIP will pay awards to whistleblowers who submit qualifying tips alleging fraud against certain government agencies or health care providers. The Justice Department stated that awards will range from $10,000 to $30,000. President Trump instead said in a press conference that the program would grant a 1% commission on the amount of fraud uncovered, although it is unclear how such percentages would be calculated given that the program is designed to provide awards before judicial investigations take place.
Regardless of which award calculation is correct, WHIP awards will be much smaller than awards already offered for whistleblowers who report fraud against the government under the False Claims Act. That law, which allows whistleblowers to file qui tam lawsuits on the government’s behalf, led to over $6.8 billion in government recoveries in the 2025 fiscal year – over $5.3 billion of which came from whistleblower tips.
Whistleblowers received over $330 million in awards – granted as percentages of successful recoveries – under the False Claims Act in fiscal year 2025 alone. WHIP, with a total budget of $25 million, will likely have a much smaller impact.
“There already exists a whistleblower law that pays 15-30% for theft of taxpayer money,” said leading whistleblower attorney David Colapinto in a tweet responding to the announcement, describing the False Claims Act program as simply “better than 1%.”
WHIP’s award determination mechanism is also unclear. The Justice Department’s FAQ website states that awards will be granted based on the Department’s sole discretion, but President Trump suggested in his press conference that he would make award determinations individually. Either structure would provide much less certainty to whistleblowers than the False Claims Act, under which awards are mandatory if a whistleblower is found to meet the applicable statutory requirements. WHIP’s confidentiality protections are also entirely discretionary, whereas False Claims Act whistleblowers can file their lawsuits under seal and thus receive judicial security.
Finally, WHIP’s basic eligibility criteria site states that only “individuals who did not actively participate in the fraud” can qualify for awards, although its FAQ site states that those with a “limited” and “minimal” role in fraud may qualify for awards at the Justice Department’s discretion. The False Claims Act only bars individuals convicted of criminal conduct in relation to the fraud from receiving awards, although an award percentage can be reduced based on culpability. This policy is based on the well-known whistleblower principle “it takes a rogue to catch a rogue,” which recognizes that individuals with some involvement in fraud are often the ones who know the most about it.
“In order for whistleblowers to come forward, they need to know what to expect,” Colapinto said. “Without that clarity, whistleblowers can have no confidence that their information will be properly utilized, or that they will receive proper credit for assisting the U.S. in such sensitive matters.
