Notes

1. Corporate integrity agreement between the Office of Inspector General of the Department of Health and Human Services and Americhoice of Pennsylvania, Inc. www.oig.hhs.gov/fraud/cia/agreements/americhoice_of_pa_inc_06292005.pdf

2. Department of Justice, Health Care Fraud Report: Enforcements, Fiscal year 1997. www.justice.gov/dag/pubdoc/health97.htm - enforcement

3. Kavilanz, Parija, “Phantom pharmacy – A growing health care fraud,” CNNMoney, June 20, 2011. http://money.cnn.com/2011/06/20/news/economy/phantom_pharmacy_healthcare_fraud/index.htm

4. Kennedy, Kelli, “Massive Nationwide Medicare Bust: 111 Charged For Scams Worth $225 Million,” Huffington Post, February 17, 2011. www.huffingtonpost.com/2011/02/17/medicare-fraud-_n_824737.html

5. Office of Inspector General, “Kickback and Physician Self-Referral,” October 21, 2010. http://oig.hhs.gov/fraud/enforcement/cmp/kickback.asp

6. Welles, Ed, “Uncovered: To many small business owners, Employers Mutual looked like the ideal health-care provider, charging premiums far below its competitors’. But in the end it turned out to be a shady operation, leaving behind millions of dollars in unpaid claims. Could your company be hit next?” CNNMoney, May 1, 2003. http://money.cnn.com/magazines/fsb/fsb_archive/2003/05/01/343406/index.htm

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