# Claims mapping for False Claims Act matters.

> Canonical URL: https://getwolf.ai/guides/claims-mapping-false-claims-act
> Published: 2026-08-23
> Last reviewed: 2026-08-24

Claims mapping is the structured practice of connecting a proposed allegation to the evidence passages, actors, transactions, and legal or contractual requirements that counsel believes are relevant.

Written and maintained by the WOLF AI product team and checked against the public sources cited on this page. It has not been reviewed by outside counsel, and it is not legal advice.

WOLF AI is a software company, not a law firm. This page is educational and is not legal advice.

## What do the numbers say?

**Rule 9(b) — Particularity standard for pleading fraud.** Federal Rule of Civil Procedure 9(b) requires that a party "must state with particularity the circumstances constituting fraud or mistake." In practice that is what turns an FCA matter into a document-organization problem: the allegation has to name specific claims, dates, and actors, each traceable to a record.

Source: [Federal Rule of Civil Procedure 9(b): pleading fraud with particularity](https://www.law.cornell.edu/rules/frcp/rule_9)

**$6.8 billion — FCA settlements and judgments, FY2025.** According to the Department of Justice, False Claims Act settlements and judgments exceeded $6.8 billion in the fiscal year ending September 30, 2025 — the highest single-year total in the history of the statute. Settlements and judgments since the 1986 amendments now exceed $85 billion.

Source: [DOJ: False Claims Act settlements and judgments exceed $6.8B in fiscal year 2025](https://www.justice.gov/opa/pr/false-claims-act-settlements-and-judgments-exceed-68b-fiscal-year-2025)

**15–30% — Statutory relator share, 31 U.S.C. § 3730(d).** Under 31 U.S.C. § 3730(d), a relator receives at least 15 percent but not more than 25 percent of the proceeds when the government intervenes, and not less than 25 percent and not more than 30 percent when it declines and the relator proceeds alone. The Department of Justice describes the typical range as 15 to 30 percent.

Source: [31 U.S.C. § 3730: Civil actions for false claims](https://uscode.house.gov/view.xhtml?req=(title:31%20section:3730%20edition:prelim))

## Who is this workflow for?

Counsel building or pressure-testing allegations who need to see, claim by claim, what is actually supported by a document and what is currently supported by nothing.

**When it is the wrong tool.** A map is not a pleading and it is not a sufficiency analysis. Whether allegations satisfy the particularity expected under Rule 9(b) in a given circuit is a legal question for counsel.

## What documents and inputs do you need?

- The proposed allegations, written in reviewable terms.
- The evidence set, with passages already linked to their sources.
- The requirements counsel considers relevant: statutory provisions, regulations, contract terms, or program conditions.

## How does the workflow actually run?

1. State the proposed allegation in reviewable terms.
2. Associate candidate documents, pages, passages, actors, and transactions.
3. Record the requirement or authority counsel considers relevant.
4. Mark gaps, conflicts, and unsupported assertions for follow-up.

## What does this look like in practice?

**Illustrative scenario.** Illustrative only. One proposed allegation: services billed at a level the documentation does not support.

1. The allegation gets its own row, phrased narrowly enough to be checked.
2. Supporting passages attach underneath: the claim lines, the corresponding notes, and the policy defining the billing level.
3. Two claim lines have no matching note at all. Those are marked as gaps rather than left to look like support.
4. A partner reads the row and sees three things at once: what supports it, what contradicts it, and what is missing.

**What this does not show.** The most valuable output of a claims map is usually the empty cell. An allegation with no attached passage is an open question, not a weak claim.

## What do you get out, and who reviews it?

- A claim-by-claim ledger tying allegations to evidence, actors, transactions, and requirements.
- An explicit list of gaps, conflicts, and unsupported assertions.
- Counsel owns the legal sufficiency of every allegation and the decision to plead it.

## Where does this approach break down?

- Software cannot decide whether every statutory element is satisfied.
- A map can expose missing support, but it cannot create evidence.
- Counsel remains responsible for legal research, theory, and filing decisions.
- Requirement citations recorded in the map are counsel’s selections, not a legal opinion produced by the product.

## Common questions

**Does claims mapping check Rule 9(b) particularity?**

No. It shows what evidence is attached to each allegation. Whether that meets the pleading standard in the relevant circuit is counsel’s determination.

**Can one passage support several allegations?**

Yes, and it usually does. The map records the relationship in both directions so a later change to one allegation does not silently orphan the evidence.

**What does a gap in the map mean?**

That nothing in the current evidence set has been connected to that assertion. It may mean the document has not been collected yet, or that the assertion needs narrowing.

## Where do these facts come from?

- [31 U.S.C. § 3729: False claims](https://uscode.house.gov/view.xhtml?req=(title:31%20section:3729%20edition:prelim))
- [31 U.S.C. § 3730: Civil actions for false claims](https://uscode.house.gov/view.xhtml?req=(title:31%20section:3730%20edition:prelim))
- [Federal Rule of Civil Procedure 9(b): pleading fraud with particularity](https://www.law.cornell.edu/rules/frcp/rule_9)
- [U.S. Department of Justice: The False Claims Act](https://www.justice.gov/civil/false-claims-act)

## Continue

- [See claims-mapping outputs](https://getwolf.ai/products#features)
- [How WOLF AI pricing works](https://getwolf.ai/pricing)
- [Book a demo](https://getwolf.ai/book-demo)
- [Security and data handling](https://getwolf.ai/security)

## Related field guides

- [FCA damages workup support](https://getwolf.ai/guides/fca-damages-workup-support)
- [A source-linked qui tam chronology builder](https://getwolf.ai/guides/qui-tam-chronology-builder)