QuitamOnline — False Claims Act whistleblower guide

FCA Original Source: Public Disclosure and the Whistleblower Exception

How the False Claims Act public disclosure bar and original-source exception work — and why independent insider knowledge matters for qui tam relators.

The public disclosure bar

The False Claims Act can bar relators from proceeding if the fraud allegations are based on publicly disclosed information — such as news reports, government audits, or certain other proceedings — unless an exception applies.

What original source means

An original source is someone who voluntarily disclosed the information to the government before it became public, or who has independent knowledge that materially adds to publicly disclosed allegations and has direct knowledge of the facts.

Courts apply these tests strictly; relators who rely only on what they read in the newspaper rarely qualify.

Why insiders matter

Employees with firsthand documents, emails, billing data, or witness knowledge of how a scheme operated are more likely to survive public disclosure challenges than those repeating already-public allegations.

Work with counsel early

Public disclosure and first-to-file issues are among the earliest motions defendants file. Experienced qui tam attorneys evaluate these bars before filing. This article is general information, not legal advice.