Troy Health Enters Groundbreaking Non-Prosecution Agreement With DOJ
November 21, 2025 | JacobiJournal.com — Troy Health, a Medicare Advantage provider, recently entered a non-prosecution agreement (NPA) with the U.S. Department of Justice, marking a first-of-its-kind healthcare resolution under the revised Corporate Enforcement Policy (CEP). The DOJ alleges Troy engaged in misconduct, including improper enrollment of Medicare beneficiaries and misuse of personal identifying information facilitated by AI tools. The agreement requires Troy Health to pay approximately $1.4 million and comply with an 18-month NPA, acknowledging its role in a scheme that impacted beneficiaries without their knowledge or consent. How Did Troy Health’s Alleged Fraud Occur? Investigators say Troy’s employees used customer lists from contract pharmacies to enroll beneficiaries into the company’s Medicare Advantage plan. Misleading calls, automated batch enrollments, and AI-driven sales tactics allegedly bypassed proper consent and documentation protocols. Some patients were auto-enrolled in batches of up to 300 at a time, and verification calls were misrepresented as genuine confirmations. The DOJ highlighted that Troy’s AI-enabled platform, Troy.ai, played a central role in orchestrating these enrollment activities. While some pharmacy staff participated, others were unaware that their customer data was being used to enroll individuals without consent. Why This NPA Matters This resolution underscores several critical trends in healthcare fraud enforcement: For healthcare providers and insurers, the case emphasizes the need for robust compliance governance, transparent self-reporting, and proactive auditing of AI-driven systems. How Companies Can Avoid Similar Compliance Pitfalls By proactively addressing these areas, organizations can reduce the risk of enforcement action and protect patient trust. For additional insights into this non-prosecution agreement and healthcare compliance trends, visit: JD Supra – Troy Health NPA. FAQs About Troy Health NPA What is a non-prosecution agreement (NPA)? An NPA is a legal agreement where the government agrees not to prosecute a company for alleged misconduct, provided the company meets certain conditions, such as paying fines or cooperating with investigations. Why did Troy Health enter an NPA with the DOJ? Troy Health admitted to allegations of enrolling Medicare beneficiaries without consent and cooperating partially with the DOJ, making it eligible for an NPA under the revised Corporate Enforcement Policy. How did Troy Health allegedly misuse AI in Medicare enrollments? Troy’s AI platform, Troy.ai, was used to manage enrollment lists and automate outreach, sometimes facilitating unauthorized beneficiary enrollments without consent or proper verification. What are the lessons for other healthcare companies? Healthcare organizations should maintain strong governance, compliance monitoring, and transparent self-reporting, especially when using AI systems that handle sensitive patient data. Stay informed and subscribe to JacobiJournal.com for up-to-date reporting on healthcare fraud and regulatory developments. 🔎 Read More from JacobiJournal.com: