 Escobar", the United States Supreme Court sought to clarify the standard for materiality under the FCA.The court unanimously upheld the implied certification theory of FCA liability and strengthened the FCA's materiality requirement.As of 2020, 29 states and the District of Columbia have false-claims laws modeled on the federal statute to protect their publicly funded programs from fraud by including qui tam provisions, which enables them to recover money at state level.