make[ ], use[ ], or eause[ ] to be made or used, a false record or statement to conceal, avoid, or decrease an obligation to pay or transmit money or property to the Government.” This subsection has been referred to as the “reverse false claims provision” of the FCA. Rabushka ex rel. United States v. Crane Co., 122 F.3d 559, 565 (8th Cir.1997). The term -“knowingly,” as used in (a)(7), “mean[s] that a person, with respect to information- — (1) has actual knowledge of the information; (2) acts in deliberate ignorance of the truth or falsity of the information; or (3) acts in reckless disregard of the truth or falsity of the information.” 31 U.S.C. § 3729(b). “[N]o proof of specific intent to defraud is required.” Id.; see also United States v. Krizek, 111 F.3d 934, 941 (D.C.Cir.1997) (<HOLDING>). In support of his claim under (a)(7), the
holding that county defendant was a person within meaning of fca for purposes of suit by private plaintiff holding an aggravated form of gross negligence or gross negligenceplus is equivalent to reckless disregard for purposes of fca holding a fetus is not a child person or individual for purposes of criminal prosecution under the reckless injury to a child statute holding that county of delaware was not a person for purposes of fca liability holding that rule 9b applies to fca