This brief discusses the application of Astra to False Claims Act allegations based upon violations of the 340B program, arguing that the FCA’s qui tam is distinct from prohibited private actions under the 340B program. It argues that outside of statutorily defined exceptions, the FCA’s capacious language does not preclude actions that are premised upon violations of other regulatory regimes; and therefore, covered entities under the 340B program may bring qui tams premised on violations of 340B regulations.