Michael Coyle, CFO of Health Corporation of America, was convicted of mail fraud, false statements under ERISA, and blackmail for concealing excessive administrative costs retained from employee benefit plan premiums. He mailed false financial schedules to cover up the scheme. The court upheld his conviction, ruling that the mailings were essential to hiding the fraudulent profits. For subcontractors, this case shows that falsifying financial documents related to benefit plans or cost reporting can result in serious federal criminal charges.
Never submit false financial schedules or cost reports to clients or benefit plan administrators—it's federal mail fraud and ERISA fraud, not just a contract dispute.