Executives Sentenced for ACA Fraud: Regulatory Compliance in Health Insurance
Two executives have been sentenced to 20 years in prison for a scheme that exploited Affordable Care Act enrollments, and the ripple effects are a compliance wake up call for carriers and agencies alike.
According to the U.S. Department of Justice, Cory Lloyd, a Florida insurance brokerage president, and Steven Strong, a Texas marketing company CEO, used fraudulent ACA enrollments to drive commission payments from insurers, with the federal government paying at least $180 million in improper subsidies tied to the activity. The case moved quickly from indictment to trial, with a federal jury in West Palm Beach convicting the pair on November 17, 2025, and sentencing announced February 18, 2026.
For industry leaders, this is not just a courtroom story. It highlights how program rules, broker compensation, and enrollment workflows can be exploited at scale when verification, monitoring, and downstream oversight are not built to catch patterns early.
What the DOJ Says Happened
Federal prosecutors described a years long operation built around enrolling consumers into fully subsidized ACA plans using false and fraudulent applications. The DOJ says the defendants targeted vulnerable individuals and used deceptive scripts and tactics to maximize subsidies and keep enrollment flowing year round. The scheme also created real harm for some consumers, including disruptions in care or coverage when they were placed into plans for which they did not qualify.
The commission angle matters for every distribution leader reading this. The DOJ’s description is blunt: the enrollments were the trigger, commissions were the payoff, and the downstream consequences landed on consumers, carriers, and taxpayers.
“Preying upon medically compromised consumers to rob hundreds of millions from taxpayer-funded programs is evil and unforgivable.”
Attorney General Pamela Bondi
Why This Case Hits the Insurance Industry So Directly
Carriers rely on clean enrollment data to price risk, manage retention, and forecast revenue. Agencies rely on consistent, compliant processes to protect their licenses and their contracts. Fraudulent enrollments sit right at the intersection, and when they scale, they can distort everything from member mix and churn to servicing costs and complaint volumes.
This case also underscores an uncomfortable truth about marketplace distribution: the system is designed for access and speed, and bad actors will look for any gap between that goal and the controls needed to protect it. If a process rewards volume, the industry has to work just as hard to reward legitimacy.
The Bigger Backdrop: Marketplace Fraud Concerns Are Not Isolated
This sentencing lands amid broader reporting and federal review of vulnerabilities in marketplace enrollment verification. In one recent watchdog test of Healthcare.gov processes, most fictitious applications submitted for coverage were initially approved even when required documentation was missing, highlighting how difficult it can be to stop improper enrollments at the point of sale.
Industry observers have also noted that agent and broker channels drive a large share of marketplace enrollments, and that relatively small per member commissions can still create significant incentive when paired with scale. In high volume environments, patterns like rapid enrollment surges, repeated plan switches, clustered addresses, and unusual churn can be early warning signals.
“We believe that the expansion of the subsidies invigorated the financial incentive to sign up as many people as possible.”
Seto Bagdoyan, Director at the Government Accountability Office
Where Controls Tend to Break Down
Most carriers and agencies already have compliance programs. The challenge is that enrollment fraud does not always look like a single dramatic event. It can look like normal production until you zoom out and connect the dots across time, geography, and broker behavior.
In marketplace business, the most common failure points are practical and operational: weak identity checks, limited verification at the point of enrollment, insufficient broker level monitoring, and delayed feedback loops between enrollment activity, member complaints, and carrier action. Once a bad pattern is established, it can scale faster than a quarterly audit cycle can catch it.
Operational Takeaways for Carriers and Agencies
- Treat enrollment velocity as a risk signal, not just a sales metric, and monitor spikes daily.
- Build broker level dashboards for churn, address reuse, complaint rates, and plan switch frequency.
- Tighten downstream oversight with documented audits, call sampling, and clear corrective action steps.
- Align compensation governance to quality, including clawback language and rapid suspension triggers.
- Create a fast path for consumer complaints to reach compliance teams, not just servicing queues.
Why Enforcement Messaging Matters
The DOJ’s public statements around this case focus on harm to vulnerable consumers and the integrity of taxpayer funded programs. That framing matters because it signals how enforcement agencies view marketplace fraud: not as paperwork errors, but as exploitation with real world impact.
The result is a higher expectation for insurers and agencies to demonstrate proactive controls, rapid response, and documented oversight. When enforcement is this visible, the best defense is not just a policy manual. It is a system that can prove it detects issues early, intervenes quickly, and prevents recurrence.
The Business Lesson: Trust Is a Distribution Asset
Marketplace distribution works because consumers, carriers, and regulators share a baseline of trust that the enrollment process reflects the consumer’s true intent and eligibility. Once that trust is shaken, everyone pays for it through higher friction, higher servicing costs, more aggressive verification, and reputational drag that spreads well beyond the bad actors.
For leaders across the insurance industry, the path forward is straightforward even if the execution is not: treat enrollment integrity as core operations, invest in monitoring that matches the speed of the marketplace, and make compliance a shared responsibility across sales, servicing, and risk.