The impact of the Department of Justice’s (DOJ) voluntary self-disclosure program was on display in the agency’s declination of an enforcement action against Florida-based health insurance company HealthSun Health Plans for apparent fraud committed by its employees and agents.

HealthSun’s legal representatives received a declination letter from the DOJ’s Fraud Section dated Oct. 25, in which the agency said it would not prosecute the company regarding the apparent fraud. The determination took into consideration multiple factors, including HealthSun’s agreement to repay approximately $53 million to the Department of Health and Human Services’ Centers for Medicare & Medicaid Services (CMS) found to have been obtained because of the alleged scheme.

The DOJ said the scheme was orchestrated by HealthSun’s former director of Medicare risk adjustment analytics, Kenia Valle Boza. On Oct. 26, Valle was charged by the agency with one count of conspiracy to commit healthcare fraud and wire fraud, two counts of wire fraud, and three counts of major fraud against the United States.