Insurers which reimbursed Omnicare for drugs during the time of this complaint
include, but are not limited to: United Healthcare, Blue Cross/Blue Shield, Health Alliance,
Humana, Aetna, and HMO Illinois.
In order to obtain reimbursement from insurers for services provided, Omnicare
typically would submit electronically a form describing the services, the service date, the total
verifications, including that the claim for reimbursement is correct and complete, and a warning
that anyone who misrepresents or falsifies material information requested by the form may be
subject to fine or imprisonment under state law.
drugs, including but not limited to Monopril, Lipitor, Accupril, Levaquin, Risperdal,
UltramlUltracet, and Abilify. As a result of their conspiracy with Defendant Manufacturers,
Omnicare billed insurers for such drugs even though claims for the drugs were based on
kickbacks, the drugs were unilaterally switched without a properly authorized physician's
dispensed as a result of the kickbacks-for-switches schemes contained false, incomplete, or
misleading information concerning facts material to the claims.
Omnicare never informed insurers that they were paying kickbacks as part of a
conspiracy to evade best price obligations, or that they conspired to and did switch drugs without
a physician's informed authorization.
By causing the concealment of these policies and practices, while knowing that
Omnicare was then submitting claims to insurers for payment, Defendant Manufacturers