In a statement to CNBC, Diane Bieri, General Counsel of the industry trade association PhRMA said, “PhRMA continues to believe that compliance with health care fraud laws is critically important. Our member companies devote significant resources to internal compliance programs and thorough investigations of any reported misconduct—activities that complement the government's enforcement efforts. While we can't speculate on trends in 'qui tam' actions, we continue to advocate for balance between appropriate enforcement and preventing unnecessary litigation that provides no new information to the government."

It could be that whistleblowers inside the industry simply have learned how to bring their cases more effectively.

But the plethora of pharmaceutical cases is one reason why some veterans of the whistleblower wars tell me they think the first wave of Wall Street whistleblower cases will be cases accusing drug company managers of insider trading ahead of merger and acquisition announcements.







Watch Eamon Javers' special series, "Bounty Hunters," all week on CNBC. On Tuesday, February 8 and Wednesday, February 9, he will report on "Squawk Box", "Squawk On The Street", and "Power Lunch. On Thursday, February 10 and Friday, February 11, he will report on "Squawk Box" and "Squawk On The Street."