According to this https://www.morganlewis.com/pubs/uptick-in-fca-investigations-and-litigation-targeting-tech-services 11/2/2020 White Collar Lawflash from the Morgan Lewis law firm,
“The False Claims Act (FCA) imposes liability on any person for making false claims or false statements in connection with a claim. 31 USC § 3729(a)(1)(A), (B). A “claim” is any request or demand for money made directly or indirectly to the government. FCA liability requires proof of materiality, meaning that the government would not have paid a claim had it known of the alleged falsehood.