Bringing DEI Qui Tams for Relators After Deloitte: From Insider Evidence to Paid Share

In February 2026, the Department of Justice drew a line between lawful and false diversity, equity, and inclusion practices. Paid resolutions with IBM, Deloitte, and Accenture Federal Services followed. False Claims Act whistleblower suits against federal contractors are now a live practice area, and the covered-conduct recitals in those settlements give relator’s counsel a working template that did not exist a year ago.

Sort an insider’s scorecards against DOJ’s stated line, and you have a certification or cost-allocation count on FAR 52.222-26. Skip the Rule 9(b) link from practice to contract, certification, and invoice, and the complaint fails. Mishandle the insider’s documents, and the public-disclosure bar is in play. File through the wrong vehicle, or in the wrong forum after Zafirov, and the share can go with the case.

Attendees leave with a falsity-sorting checklist, an annotated disclosure-statement outline under 31 U.S.C. § 3730(b)(2), an organization–insider term sheet, a state-count screening chart, and a share-negotiation memo outline, plus a working view of the 20% pre-litigation share and declined-case value after the Justice Manual § 4-4.111 revision. This is relator-side judgment — which evidence to lead with, which vehicle to use, what a share is worth — not a doctrine walk-through.