The United States Needs a Formal Pandemic Fraud Recovery Strategy

American taxpayers deserve a proactive effort to pursue the losses that remain cost effective and achievable

When governments move quickly during crises, they accept risk. That tradeoff is unavoidable. The COVID-19 pandemic required governments to push unprecedented volumes of money into the economy at unprecedented speed. It created the largest fraud event in our nation’s history.

The policy question is whether governments treat pandemic losses as permanent or whether they organize a serious effort to recover what remains recoverable.

The United Kingdom has answered that question more directly than the United States. In late 2025, the U.K. government released the final report of its Covid Counter Fraud Commissioner, commissioned to examine the scale of pandemic losses and recommend a national strategy for pursuing recoveries and preventing similar failures in future crises.

The report estimates that roughly £10.9 billion in pandemic support was lost to fraud and error, and approximately £1.8 billion has been recovered so far. The Commissioner’s central conclusion is not that recovery has failed, but that the government’s recovery effort has been uneven and incomplete—and that substantial recoverable losses remain if the government acts with sufficient coordination and urgency.

That conclusion carries important implications for the United States. American pandemic relief programs were far larger and more fragmented than their British counterparts. Federal and state programs delivered trillions of dollars through dozens of agencies, financial institutions, and contractors. The Government Accountability Office and Inspectors General have estimated that fraud losses across federal programs reached hundreds of billions of dollars. Yet despite the scale of those losses, the United States has never organized a unified national recovery strategy comparable to the one now emerging in the United Kingdom. Instead, recovery efforts remain distributed across agencies, inspectors general, and prosecutors, each pursuing cases within their own programmatic boundaries.

The British experience illustrates why that approach is insufficient. The Covid Counter Fraud Commissioner found that recovery activity varied significantly across government departments and that some departments were slow to pursue aggressive recovery efforts even after fraud risks became clear.

Fragmentation meant that the government lacked a clear picture of what was recoverable, where enforcement resources should be concentrated, and which recovery strategies were producing returns. Without a central mandate and shared expectations, recovery work competed with other operational priorities and often lost.

This dynamic is familiar in the United States. Pandemic relief programs were administered across multiple federal agencies, state governments, and financial institutions. Each program developed its own investigative posture and recovery strategy. Some agencies built sophisticated analytics and recovery teams. Others relied primarily on criminal enforcement, which is resource-intensive and necessarily selective. The result is a patchwork system in which recoveries occur episodically rather than systematically.

The U.K. report identifies another structural reality that should shape American policy: time is the decisive factor in fraud recovery. The Commissioner warns that the most effective window for recovering fraudulent payments occurs soon after a crisis, before evidence deteriorates and funds are moved beyond reach. When recovery efforts lag behind the pace of spending, the government effectively locks in avoidable losses.

The United States is already confronting this reality. Pandemic funds have circulated through complex financial channels, shell companies have dissolved, and records have become harder to reconstruct. Every year that passes reduces the probability that funds can be traced and recovered. That does not mean recovery is futile; it means recovery must be organized and prioritized while meaningful opportunities still exist.

The British government has also recognized that large-scale recovery cannot rely solely on criminal prosecutions. Criminal enforcement plays an essential role in deterring fraud and punishing the most serious offenders, but it is too slow and expensive to serve as the primary recovery mechanism for mass-scale program abuse. The Commissioner therefore proposed a voluntary repayment scheme that would allow individuals and businesses who improperly received pandemic support to return funds within a defined window. The goal is to create a low-cost mechanism for recovering money without requiring a full investigative process in every case.

This proposal reflects a pragmatic understanding that recovery requires a range of tools—from voluntary compliance to civil recovery to criminal enforcement—rather than a single investigative pathway.

Legal authorities and time limits also shape the feasibility of recovery. Recognizing that pandemic fraud often involves complex financial structures and delayed discovery, the United Kingdom has moved to extend the period during which authorities can pursue COVID-related fraud cases.

This legislative adjustment acknowledges a basic reality of crisis spending: the speed of disbursement often exceeds the government’s ability to detect fraud in real time, meaning that meaningful enforcement frequently occurs years later. In the United States, we have extended the statute of limitations for pandemic fraud prosecutions in small business loan programs, but nowhere else. Congress must act to change this.

The report further highlights the importance of incentives inside government. Departments often struggle to justify dedicating staff and resources to recovery efforts when the financial benefits flow back to the central treasury rather than to the department that undertook the work. The Commissioner therefore recommends allowing departments to retain a portion of recovered funds to support additional fraud prevention and recovery activities.

Without such incentives, recovery becomes an unfunded mandate that competes with operational priorities.

Data access and transparency are another central theme. The report attributes many recovery challenges to the government’s inability to access and analyze relevant data quickly, particularly when funds flowed through third-party institutions. It recommends reforms to enable faster data sharing during crises and to establish minimum transparency requirements for organizations receiving public funds.

The logic is straightforward: if investigators cannot see how funds moved, they cannot recover them.

Finally, the report recognizes that recovery efforts lose momentum without sustained oversight. To prevent the issue from fading as public attention shifts, it recommends establishing a minister-chaired scrutiny panel that would review progress regularly for several years.

The purpose of such oversight is to ensure that departments remain accountable for pursuing recoveries and implementing reforms long after the crisis has passed.

Taken together, these recommendations outline a model that the United States should examine seriously.

A National Pandemic Fraud Recovery Initiative would identify recoverable losses, prioritize high-yield recovery strategies, and align investigative, legal, and analytical resources around a common objective: maximizing recoveries while strengthening the government’s ability to prevent similar losses in future crises.

Such an initiative would begin with a comprehensive assessment of remaining recovery opportunities across major pandemic programs. It would establish a central coordinating function to align agencies and share data. It would deploy a range of recovery mechanisms, including voluntary repayment programs, civil recovery actions, and targeted criminal enforcement. It would ensure that agencies have both the legal authorities and the financial incentives needed to pursue recoveries. And it would establish a governance structure capable of sustaining attention to the problem over multiple years.

The broader lesson from the United Kingdom is that fraud recovery should not be treated as an afterthought to emergency spending. It is part of the lifecycle of crisis programs. When governments distribute funds rapidly to stabilize an economy, they must also plan for the inevitable task of recovering funds that were obtained improperly.

The United States responded to the pandemic with extraordinary fiscal speed and scale. That response helped avert a deeper economic collapse. But speed created vulnerabilities that criminal networks exploited on an industrial scale. Accepting those losses as permanent would represent a quiet but consequential policy choice.

Other governments have concluded that such losses deserve a more deliberate response. The United States should reach the same conclusion—and act before the window for meaningful recovery closes.