Which of the following indicates civil liability under the FCA?

The correct choice highlights that billing mistakes can lead to civil liability under the False Claims Act (FCA). The FCA imposes liability on individuals or entities that submit false or fraudulent claims for payment to the government. Billing mistakes can fall under this category when, for example, a healthcare provider inadvertently submits incorrect information that results in overpayment or payment for services not rendered. These errors may not only reflect negligence but, depending on the circumstances, could also indicate a lack of reasonable care in ensuring that claims are accurate and compliant with applicable regulations. As such, these mistakes can expose entities to legal action and the possibility of significant financial penalties.

In contrast, the other options do not inherently indicate civil liability under the FCA. Complete corporate transparency, for instance, is a practice that enhances accountability and may actually help prevent violations. Similarly, internal audits serve as a compliance mechanism aimed at detecting and correcting potential issues before they escalate to the point of civil liability. Likewise, employee recognition programs are intended to promote ethical behavior and compliance within organizations, rather than being indicative of liability. Therefore, the presence of billing mistakes directly correlates with the potential for civil liability under the FCA, making it the correct answer.