Indictment: Anthem Fraud Investigator Arrested in Fraud Investigation

Case 2:18-cr-00288-SVW Document 1 Filed 05/17/18 Page 1 of 13 Page ID #:1
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8 UNITED STATES DISTRICT COURT
9 FOR THE CENTRAL DISTRICT OF CALIFORNIA
10 October 2017 Grand Jur
11 UNITED STATES OF AMERICA CR No. 18~+,~ v ~O Z88s~ Vv
12 Plaintiff, I N D I C T M E N T
13 v. [18 U.S.C. ~ 1349: Conspiracy to

Commit Health Care Fraud;
14 ROSHANAK KHADEM, 18 U.S.C. ~ 1347: Health Care
aka "Roxanne Khadem," Fraud; 18 U.S.C. ~ 2; Aiding and
15 aka "Boxy Khadem," Abetting and Causing an Act to Be
GARY JIZMEJIAN, Done; 18 U.S.C. ~ 982(a)(7),
16 ROBERTO MARIANO, 28 U.S.C. ~ 2461(c) Criminal
MARINA SARKISYAN, Forfeiture]
17 LUCINE ILANGEZYAN,
aka "Lulu Ilangezyan,"
18
19 Defendants.
20
21 The Grand Jury charges:

i
22 COUNT ONE
23 [18 U.S.C. ~ 1349]
24 A. INTRODUCTORY ALLEGATIONS
25 1. Beginning in or around July 2008, and continuing through in
26 or around April 2016, R&R Med Spa was a clinic located at 12030
27 Riverside Drive, Suite A, Valley Village, California, within the
28 Central District of California.

1 2. Beginning in or around February 2016 and continuing through

a
2 in or around April 2017, Nu-Me Aesthetic and Anti-Aging Center ("Nu-
3 Me Spa") was a clinic located at 20301 Ventura Boulevard, Suite 250,
4 Woodland Hills, California, within the Central District of California
5 (collectively with R&R Med Spa, the "Clinics").
6 3. At all times relevant to this Indictment, defendant
7 ROSHANAK KHADEM; also known as ("aka") "Roxanne Khadem" and "Roxy
8 Khadem" ("KHADEM"), was the owner and operator of the Clinics.
9 4. At all times relevant to this Indictment, defendant GARY
10 JIZMEJIAN ("JIZMEJIAN") was a Senior Investigator in the Special
11 Investigations Unit for the health insurance company Anthem Blue
12 Cross ("Anthem").
13 5. At all times relevant to this Indictment, defendant ROBERTO
14 MARIANO ("MARIANO") was a physician and an operator of the Clinics.
15 6. Beginning no later than in or around January 2011, and
.16 continuing through in or around January 2016, defendant MARINA
17 SARKISYAN ("SARKISYAN") was an employee and manager of the Clinics.
18 7. At all times relevant to this Indictment, defendant LUCINE
19 ILANGEZYAN, aka "Lulu Ilangezyan" ("ILANGEZYAN"), was an employee and
20 the insurance biller for the Clinics.
21 8. Beginning in or around July 2013, and continuing through in
22 I or around April 2016, co-conspirator 1 ("CC-1") was an employee of
23 the Clinics.
24 The Health Insurance Companies
25 9. At all times relevant to this Indictment:
26 a. The following were health care benefit programs
27 affecting commerce: Anthem; International Longshore and Warehouse
28 Union - Pacific Maritime Association Benefit Plan ("ILWU-PMA");
2
1 Aetna; United Healthcare; CIGNA Health Management ("CIGNA"); Health
2 Net; Federal Employees Health Benefits Program ("FEHBP"); Blue Shield
3 of California ("Blue Shield") (collectively, the "Health Insurance
4 Companies").
5 b. The Health Insurance Companies would reimburse
6 physicians and other health care providers for medical services,
7 including, physician examinations, allergy testing, ultrasounds,
8 nerve conduction tests, vascular studies, and other medically
9 necessary services that were rendered to individuals who received
10 insurance coverage from the Health Insurance Companies
11 ("beneficiaries").
12 c. The Health Insurance Companies would not reimburse
13 physicians and other health care providers for medically unnecessary
14 services and for cosmetic procedures provided to beneficiaries,
15 including skin rejuvenation procedures, facials, laser hair removal,
16 and Botox injections.
17 Anthem Special Investigations Unit
18 10. At all times relevant to this Indictment:
19 a. The Special Investigations Unit ("SIU") was a
20 department within Anthem that was responsible for detecting and
21 investigating fraud committed by health care providers against
22 Anthem. The SIU maintained offices in Woodland Hills and Newbury
23 Park, California, within the Central District of California.
24 b. .Investigators within the SIU, including defendant
25 JIZMEJIAN, were responsible for investigating fraud that was
26 committed by health care providers and recovering money due to Anthem
27 from those health care providers. In some instances, Anthem SIU
28 Investigators would refer health care fraud cases involving
3
1 fraudulent claims submitted to Anthem to federal, state, and local
2 law enforcement agencies for criminal prosecution. Anthem SIU
3 Investigators would then work with law enforcement agencies to assist
4 in the prosecution of such cases.
5 B. THE OBJECT OF THE CONSPIRACY
7 continuing through in or around April 2017, in Los Angeles County,
8 within the Central District of California, and elsewhere, defendants
9 KHADEM, JIZMEJIAN, MARIANO, SARKISYAN, and ILANGEZYAN, together with
10 CC-1, and others known and unknown to the Grand Jury, knowingly
11 combined, conspired, and agreed to commit health care fraud, in
12 violation of Title 18, United States Code, Section 1347.
13 C. THE MANNER AND MEANS OF THE CONSPIRACY
14 12. The object of the conspiracy was carried out, and to be
15 carried out, in substance as follows:
16 a. Individuals associated with the Clinics, including
17 ( defendants KHADEM and SARKISYAN, would induce beneficiaries to visit.
18 the Clinics to receive cosmetic procedures.
19 b. Defendants KHADEM and SARKISYAN would inform
20 beneficiaries that they could receive free or discounted Cosmetic
21 procedures if the beneficiaries provided their insurance information
22 to the Clinics.
23 c. Once they received the insurance information from the
24 beneficiaries, defendants KHADEM, MARIANO, SARKISYAN, and ILANGEZYAN
25 would submit, and cause to be submitted, false and fraudulent claims
26 for reimbursement for medical services to the Health Insurance
27 Companies. At times, defendants KHADEM, MARIANO, SARKISYAN, and
28 ILANGEZYAN would submit, and cause to be submitted, false and
D
1 I~fraudulent claims to the Health Insurance Companies for unnecessary
2 medical procedures. At other times, defendants KHADEM, MARIANO,
3 SARKISYAN, and ILANGEZYAN would submit, and cause to be submitted,
4 false and fraudulent claims to the Health Insurance Companies for
5 medical procedures that were never provided to the beneficiaries.
6 d. After the Health Insurance Companies issued payment
7 based on the false and fraudulent claims, defendants KHADEM,
8 ~ SARKISYAN, and ILANGEZYAN would calculate a "credit," which would be
9 a portion of the amount that the Health Insurance Companies had paid,
10 and give this credit to the beneficiaries to use to receive free or
11 discounted cosmetic procedures from the Clinics. Defendant MARIANO
12 would provide cosmetic procedures to beneficiaries at the Clinics.
13 e. Defendant KHADEM, together with CC-1, would recruit
14 doctors to work part-time at the Clinics (the "recruited doctors").
15 Defendant KHADEM and CC-1 would open bank accounts for the recruited
16 doctors and would retain signatory authority on _the accounts.
17 Defendant KHADEM and CC-1 would cause the addresses for the recruited
18 doctors on file with the Health Insurance Companies to be changed to
19 the addresses of the Clinics or post office boxes near the Clinics,
20 so that defendant KHADEM and CC-1 would have access to the payment
21 checks from the Health Insurance Companies. Defendants KHADEM,
22 MARIANO, and SARKISYAN, together with CC-1, would keep for themselves
23 a percentage of the funds that the Health Insurance Companies paid
24 for claims that were submitted under the names of the recruited
25 doctors.
26 f. Defendant JIZMEZJIAN would provide confidential
27 information relating to Anthem to defendant KHADEM and CC-1, knowing
28 and intending that defendant KHADEM would use the confidential

1 information to submit and cause to be submitted false and fraudulent
2 claims for reimbursement to Anthem.
3 i. For example, in or around September 2012,
4 defendant JIZMEJIAN provided an insurance billing code (known as a
5 "CPT Code") to defendant KHADEM for a medical test that defendant
6 JIZMEJIAN knew defendant KHADEM could bill fraudulently, and receive
7 large reimbursements from Anthem, without Anthem detecting the

1
8 fraudulent claims. Defendant JIZMEJIAN provided defendant KHADEM
9 with the CPT Code 86256 and instructed defendant KHADEM to submit
10 claims under that CPT Code to Anthem. After defendant KHADEM
11 informed defendant JIZMEJIAN that she had provided, and caused to be
12 provided, the billing codes to the biller, defendant ILANGEZYAN,
13 defendant JIZMEJIAN instructed defendant KHADEM to immediately begin
14 submitting bills to Anthem at high volumes, saying, "start right
15 away, especially 86256 @ 99 units or more."
16 ii. From in or around October 2012 to in or around
17 March'2016, defendants KHADEM and ILANGEZYAN submitted and caused to
18 i, be submitted approximately $992,091 in false and fraudulent claims to
19 Anthem for CPT Code 86256, and Anthem paid approximately $698,863 on
20 those false and fraudulent claims.
21 g. Defendant JIZMEJIAN would act to prevent the Health
22 Insurance Companies, including Anthem, from detecting the fraud at
23 the Clinics, including:
24 i. Defendant JIZJEJIAN provided advice to defendant
25 KHADEM and CC-1 on how to handle fraud investigations into the
26 Clinics by Anthem and other Health Insurance Companies, including by
27 telling defendant I~-iADEM how to evade inquiries from investigators
28 from the Health Insurance Companies;

1 ii. Defendant JIZMEJIAN advised defendant KHADEM and
2 CC-1 to change the addresses for recruited doctors so that SIU
3 Investigators would not associate the recruited doctors with
4 defendant KHADEM and the Clinics;
5 iii. Defendant JIZMEJIAN diverted the attention of
6 other Anthem SIU Investigators away from the recruited doctors that
7 were working at the Clinics;
8 iv. Defendant JIZMEJIAN closed investigations that
9 defendant JIZMEJIAN had previously opened within the Anthem SIU
10 system on recruited doctors for the Clinics without making any
11 findings of fraud; and
12 v. Defendant JIZMEJIAN recommended that one of the
13 recruited doctors be removed from Anthem's Flagged Provider List.
14 h. Defendant JIZMEJIAN would also intervene with other
15 employees at Anthem to assist defendant KHADEM and CC-1 to correct
l6 problems that were impeding the ability of the Clinics to receive
17 payment from Anthem, including by expediting the process of changing
18 the mailing address for one of the recruited doctors so that
19 reimbursement checks from Anthem would be sent to defendant KHADEM
20 and CC-1 at a post office box across the street from R&R Med Spa. _
21 i. After in or around September 2015, when defendant
22 JIZMEJIAN learned from internal Anthem sources that there was a
23 federal criminal investigation into R&R Med Spa, defendant JIZMEJIAN
24 would disclose internal Anthem information about the federal criminal
25 investigation to defendant KHADEM and CC-1 in order to allow
26 defendant KHADEM to take steps to prevent the discovery and
27 successful prosecution of the fraud at the Clinics.
28
7
1 j. In exchange for defendant JIZMEJIAN's actions on
2 behalf of the Clinics, defendant KHADEM and CC-1 would make cash
3 payments to defendant JIZMEJIAN.
4 13. From January 2012 to April 2017, the Clinics submitted
5 claims to the Health Insurance Companies totaling at least
6 $20,000,000 and the Health Insurance Companies paid approximately
7 $8,000,000 on those claims.
10
11
12
13
14
15
16
17
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19
20
21
22
23
24
25
26
27
28
0
1 COUNTS TWO THROUGH FOURTEEN
2 [18 U.S.C. ~~ 1347, 2]
3 14. The Grand Jury incorporates by reference and re-alleges
4 paragraphs 1 through 10 and 12 through 13 above of this Indictment as
5 though set forth in their entirety herein.
6 A. THE SCHEME TO DEFRAUD
8 continuing through in or around April 2017, in Los Angeles County,
9 within the Central District of California, and elsewhere, defendants
10 KHADEM, JIZMEJIAN, MARIANO, SARKISYAN, and ILANGEZYAN, together with
11 CC-1, and others known and unknown to the Grand Jury, knowingly,
12 willfully, and with intent to defraud, executed, and attempted to
13 execute, a scheme and artifice: (a) to defraud health care benefit
14 programs, namely the Health Insurance Companies, as to material
15 matters in connection with the delivery of, and payment for, health
16 '. care benefits, items, and services; and (b) to obtain money from the
17 Health Insurance Companies by means of materially false and
18 fraudulent pretenses and representations and the concealment of
19 material facts in connection with the delivery of, and payment for,
20 health care benefits, items, and services.
21 B. MEANS TO ACCOMPLISH THE SCHEME TO DEFRAUD
22 16. The fraudulent scheme operated, in substance, as described
23 in paragraphs 12 and 13 of this Indictment.
24 C. EXECUTIONS OF THE FRAUDULENT SCHEME
25 17. On or about the dates set forth below, within the Central
26 District of California, and elsewhere, defendants KHADEM, JIZMEJIAN,
27 ~ MARIANO, SARKISYAN, and ILANGEZYAN, together with CC-1, and others
28 known and unknown to the Grand Jury, knowingly and willfully executed
9
1 and attempted to execute the fraudulent scheme described above, by
2 submitting and causing to be submitted to the Health Insurance
3 Companies identified below the following false and fraudulent claims:
4
COUNT:: BEIVE. SERVICE - 'CPT INS: SERVICE CLAIM CLAIM
5 CODE CO: DATE DATE AMOUNT
6
TWO F.C. 95912 - Anthem 9/11/13 3/5/14 $1,088.32
7 Nerve
Conduction
8 Test
9
THREE R.M. 93925 - Cigna 12/16/13 4/21/14 $285.00
10 Vascular
Ultrasound
11
12 FOUR R.M. 93970 - Cigna 12/16/13 4/21/14 $350.00

Duplex Scan
13 of Extremity
Veins
14
15 FIVE M.C. 86256 - Anthem 2/17/14 3/5/14 $4,620.75

Flourescent
16 Antibody;
Titer
17
18 SIX T.A. 86256 - Anthem 2/18/14 3/5/14 $4,&78.30

Flourescent
19 Antibody;
Titer
20
21 SEVEN M.C. 95911 - Anthem 7/8/14 7/9/14 $855.00

Nerve
22 Conduction
Test
23
24 EIGHT A.J. 95004 - Anthem 7/12/14 7/16/14 $1,550.00

Percutaneous
25 Tests with
Allergenic
26 Extracts
27
28
10
Case 2:18-cr-00288-SVW Document 1 Filed 05/17/18 Page 11 of 13 Page ID _ #:11 F
1
COUNT BENE. SERVICE - CPT INS. SERVICE CLP,IM CLAIM..
2 CODE CO. DATE DATE AMOUNT
3
NINE J.J. 10061 - Anthem S/16/14 11/3/14 $625.00
4 Incision and
Drainage of
5 Abscess
6
TEN T.A. 86256 - Anthem 2/16/15 2/17/15 $2,956.80
7 Flourescent
Antibody;
8 Titer
9
ELEVEN R.M. 95912 - Cigna 5/9/15 6/27/15 $650.00
10 Nerve
Conduction
11 Test
12
TWELVE K.G. 95912 - Cigna 8/28/15 9/2/15 $650.00
1~3 Nerve
Conduction
14 Test
15
THIR- S.L. 95004 - FEHBP/ 4/2/16 4/13/16 $1,848.00
16 TEEN Percutaneous Blue
Tests with Shield
17 Allergenic
Extracts
18
19 FOUR- Y.L. 99204 - FEHBP/ 2/29/16 4/13/16 $298.00

TEEN Office Visit Blue
20 Shield
21
22
23
24
25
26
27
28
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Case 2:18-cr-00288-SVW Document 1 Filed 05/17/18 Page
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12 of 13 Page ID #:12
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1 FORFEITURE ALLEGATION
2 [18 U.S.C. ~ 982(a)(7) and 28 U.S.C. ~ 2461(c)]
3 1. Pursuant to Rule 32.2(a}, Fed. R. Crim. P., notice is
4 hereby given that the United States will seek forfeiture as part of
5 any sentence in accordance with Title l8, United States Code, Section
6 982(a)(7) and Title 28, United States Code, Section 2461(c), in the
7 event of any defendant's conviction under any of Counts One through
8 Fourteen of this Indictment. The defendant so convicted shall
9 forfeit the following:
10 a. All right, title, and interest in any and all
11 property, real or personal, that constitutes or is derived, directly
12 or indirectly, from the gross proceeds traceable to the commission of
13 any offense of conviction; and
14 b. To the extent such property is not available for
15 forfeiture, a sum of money equal to the total value of the property
16 described in subparagraph a.
17 2. Pursuant to Title 21, United .States Code, Section 853(p),
18 as incorporated by Title 28, United States Code, Section 2461(c), and
19 Title 18, United States Code, Section 982(b), the convicted defendant
20 shall forfeit substitute property, up to the total value of the ~
21 property described in the preceding paragraph if, as a result of any
22 act or omission of. the defendant, the property described in the
23 preceding paragraph, or any portion thereof (a) cannot be located
24 upon the exercise of due diligence; (b) has been transferred, sold to
25 or deposited with a third party; (c) has been placed beyond the
26 jurisdiction of the Court; (d) has been substantially diminished in
27
28
12
1 value; or (e) has been commingled with other property that cannot be
2 divided without difficulty.
4 A TRUE BILL
6
Foreperson
7
8 TRACY L. WILKISON
Attorney for the United States,
9 Acting Under Authority Conferred
by 28 U.S.C. ~ 515
10
li
12 LAWRENCE S. MIDDLETON
Assistant United States Attorney
13 Chief, Criminal Division
14 RANEE A. KATZENSTEIN
15 Chief, Major Frauds Section
16 STEPHEN A. CAZARES
i Assistant United States Attorney
17 Deputy Chief, Major Frauds Section
18 ALEXANDER F. PORTER
19 Major Frauds Section
20
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Case 2:18-cr-00288-SVW Document 1 Filed 05/17/18 Page 1 of 13 Page ID #:1

8 UNITED STATES DISTRICT COURT

9 FOR THE CENTRAL DISTRICT OF CALIFORNIA

10 October 2017 Grand Jur

11 UNITED STATES OF AMERICA CR No. 18~+,~ v ~O Z88s~ Vv

13 v. [18 U.S.C. ~ 1349: Conspiracy to

21 The Grand Jury charges:

23 [18 U.S.C. ~ 1349]

25 1. Beginning in or around July 2008, and continuing through in

27 Riverside Drive, Suite A, Valley Village, California, within the

28 Central District of California.

1 2. Beginning in or around February 2016 and continuing through

3 Me Spa") was a clinic located at 20301 Ventura Boulevard, Suite 250,

4 Woodland Hills, California, within the Central District of California

5 (collectively with R&R Med Spa, the "Clinics").

6 3. At all times relevant to this Indictment, defendant

7 ROSHANAK KHADEM; also known as ("aka") "Roxanne Khadem" and "Roxy

8 Khadem" ("KHADEM"), was the owner and operator of the Clinics.

9 4. At all times relevant to this Indictment, defendant GARY

10 JIZMEJIAN ("JIZMEJIAN") was a Senior Investigator in the Special

11 Investigations Unit for the health insurance company Anthem Blue

13 5. At all times relevant to this Indictment, defendant ROBERTO

14 MARIANO ("MARIANO") was a physician and an operator of the Clinics.

15 6. Beginning no later than in or around January 2011, and

.16 continuing through in or around January 2016, defendant MARINA

17 SARKISYAN ("SARKISYAN") was an employee and manager of the Clinics.

18 7. At all times relevant to this Indictment, defendant LUCINE

19 ILANGEZYAN, aka "Lulu Ilangezyan" ("ILANGEZYAN"), was an employee and

20 the insurance biller for the Clinics.

21 8. Beginning in or around July 2013, and continuing through in

22 I or around April 2016, co-conspirator 1 ("CC-1") was an employee of

24 The Health Insurance Companies

25 9. At all times relevant to this Indictment:

26 a. The following were health care benefit programs

27 affecting commerce: Anthem; International Longshore and Warehouse

28 Union - Pacific Maritime Association Benefit Plan ("ILWU-PMA");

1 Aetna; United Healthcare; CIGNA Health Management ("CIGNA"); Health

2 Net; Federal Employees Health Benefits Program ("FEHBP"); Blue Shield

3 of California ("Blue Shield") (collectively, the "Health Insurance

5 b. The Health Insurance Companies would reimburse

6 physicians and other health care providers for medical services,

7 including, physician examinations, allergy testing, ultrasounds,

8 nerve conduction tests, vascular studies, and other medically

9 necessary services that were rendered to individuals who received

10 insurance coverage from the Health Insurance Companies

12 c. The Health Insurance Companies would not reimburse

13 physicians and other health care providers for medically unnecessary

14 services and for cosmetic procedures provided to beneficiaries,

15 including skin rejuvenation procedures, facials, laser hair removal,

16 and Botox injections.

17 Anthem Special Investigations Unit

18 10. At all times relevant to this Indictment:

19 a. The Special Investigations Unit ("SIU") was a

20 department within Anthem that was responsible for detecting and

21 investigating fraud committed by health care providers against

22 Anthem. The SIU maintained offices in Woodland Hills and Newbury

23 Park, California, within the Central District of California.

24 b. .Investigators within the SIU, including defendant

25 JIZMEJIAN, were responsible for investigating fraud that was

26 committed by health care providers and recovering money due to Anthem

27 from those health care providers. In some instances, Anthem SIU

28 Investigators would refer health care fraud cases involving

1 fraudulent claims submitted to Anthem to federal, state, and local

2 law enforcement agencies for criminal prosecution. Anthem SIU