There are very few limitations on Government Employees blowing the whistle and being relators through the False Claims Act. The Sixth Circuit found in United States v. A.D. Roe Co., 186 F.3d 717, 722 n. 5 (6th Cir. 1999), that “[N]o court has accepted the argument that government employees per se can never be relators in a qui tam action.” This holding is consistent with the Eleventh Circuit's holding from the 1991 case, U.S. ex rel. Williams v. NEC Corp., 931 F.2d 1493 (11th Cir. 1991), wherein the Eleventh Circuit also decided that “nothing in the False Claims Act prohibits a government employee from filing a qui tam action based upon information acquired while working for the government.”. A Fifth Circuit case from 2012, U.S. ex rel. Little and Arnold v. Shell Exploration & Prod., et al., 2012 WL 3089777 (5th Cir. 2012), found that government employees are considered private persons and could bring a qui tam actions. This was after the defendant filed to dismiss on the ground that since the relators were government employees, they were not private persons. The court decided that since the relators reported the fraud to their agency and the agency did nothing, they were free to bring a claim and in that case, were considered the original source of information.
In another recent case decided by a federal district court, U.S. ex rel. Griffith v. Conn, CIV. 11-157-ART, 2015 WL 779047, at *1 (E.D. Ky. 2015), the court raise a new issue which would be the only one directly relevant to being a government employee, and that is the fact that it is part of their duty to report the fraud, and why should they be rewarded more for doing something that is already expected from them. This means that there is no way for them to meet the requirement of “voluntarily” providing information, as they had a duty as part of their job description and per their agency manual. One of the relators in the case was able to continue the claim as she had resigned from the agency before the claim and as such was not bound by the manual or her job description. This means that there are some very specific scenarios where an employee would be limited. This is though in the Sixth Circuit, and there are exceptions, so this inquiry of whether a government relator can provide information "voluntarily" if their duties require it, is fact-intensive and dependent.
There have been another few instances where this was slightly limited, but it was due to the fact that there was a public disclosure issue and not related to the fact that they were government employees.