Corporate Misconduct Accountability Project
FTC Enforcement Action · Insurance Fraud
Fake Insurance, Real Damage: How Top Healthcare Options Scammed Americans Out of Tens of Millions
A Florida telemarketing network built a scheme to intercept Americans searching for Obamacare coverage, selling them junk plans that left families with crushing medical debt.
🔴 CRITICAL SEVERITY
$10M+
Tens of millions in consumer harm since 2020
9
Corporate shell entities in the scheme
$5,417
One consumer’s ER bill after plan denied coverage
$8,000+
Another family’s unexpected medical bills
$500/mo
Monthly fees charged for useless plans
$50
Max ER coverage on one plan sold as “insurance”
TL;DR
Top Healthcare Options and its network of nine interconnected companies built a predatory telemarketing machine that targeted Americans searching for Affordable Care Act health insurance. They intercepted consumers through fake websites mimicking HealthCare.gov, called them with scripted lies about PPO plans and low copays, and sold them junk fixed-indemnity products that covered almost nothing. When a woman who asked for ER coverage went to the emergency room after an allergic reaction, her plan paid zero. Another family owed over $8,000 in unexpected bills. A man needing a $27,000-per-month life-sustaining medication got no coverage at all. These companies collected hundreds of dollars per month from vulnerable people, then made it nearly impossible to cancel. This is fraud, and it caused real, devastating harm to real people.
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Core Allegations
What They Did
Deceptive sales, misrepresentation, and concealment · 8 points
▼
| 01 | Defendants operated a deceptive telemarketing scheme targeting consumers searching for Obamacare and ACA-compliant health insurance, intercepting them through fake lookalike websites before calling with scripted false promises. | high |
| 02 | Sales agents falsely told consumers they were purchasing comprehensive PPO health insurance with real provider networks, no deductibles, and low fixed copays, when in fact they were selling fixed indemnity plans that paid trivial fixed sums regardless of actual costs. | high |
| 03 | Defendants purchased tens of thousands of consumer leads from websites named to mimic government exchanges, including “Obamacare-Health-Plans.com” and “KentuckyHealthPlans.org,” tricking consumers into believing they were applying through official channels. | high |
| 04 | Agents actively discouraged consumers from enrolling in legitimate ACA marketplace plans by falsely claiming those plans were too expensive, had excessive deductibles, or that consumers would not qualify for them. | high |
| 05 | Defendants used a scripted “verification” process conducted only after collecting payment information, during which consumers were told not to ask questions and were pressured to scroll past and sign electronic agreements without reading them. | high |
| 06 | Even the verification disclosures were false and misleading: agents told consumers the plan was not “major medical” only because it lacked a deductible and pregnancy coverage, obscuring the far more significant fact that it transferred no risk and capped benefits at pennies on the dollar. | high |
| 07 | Consumers who tried to cancel encountered long hold times, argumentative representatives, and in many cases were forced to freeze their credit cards or file complaints to stop being charged. | med |
| 08 | An FTC undercover investigator confirmed the deception firsthand: a THO agent sold him a fixed indemnity plan labeled “regular insurance” and a “no-deductible PPO,” promising $10 doctor visit copays and nationwide coverage. None of these representations were true. | high |
💰 Profit Over People
Revenue prioritized over ethics · 5 points
▼
| 01 | Defendants charged consumers enrollment fees from $50 to $150 plus recurring monthly fees up to $500, collecting hundreds of dollars monthly for products that covered almost none of consumers’ actual medical costs. | high |
| 02 | Individual defendants used corporate bank accounts to pay personal luxury expenses including designer handbags, jewelry, luxury vehicles, designer brand purchases, sports game tickets, and international travel, funded by consumer payments. | high |
| 03 | The network paid hundreds of thousands of dollars to purchase consumer leads from deceptive lookalike websites, reinvesting fraud proceeds into expanding the fraud operation itself. | high |
| 04 | Agents used high-pressure urgency tactics, falsely claiming discounted prices would expire the same day to override hesitation and prevent consumers from researching what they were buying. | med |
| 05 | Defendants were aware of consumer complaints about their products and practices but continued operating without remediation, knowingly continuing to cause harm. | high |
📉 Economic Fallout
Financial harm to consumers · 6 points
▼
| 01 | Defendants caused tens of millions of dollars in financial harm to consumers since 2020, per the FTC’s own assessment in the complaint. | high |
| 02 | One consumer who specifically requested ER coverage went to the emergency room for an allergic reaction and was billed $5,417. Her plan, sold as a PPO, would have covered at most $50 of that bill. | high |
| 03 | Another consumer who sought treatment for a shoulder injury and her son’s broken arm received a $50 check in the mail and a small discount, then owed over $8,000 in unexpected medical bills. | high |
| 04 | A consumer needing a $27,000-per-month life-sustaining medication asked explicitly for a plan that would cover it. The agent sold him a plan that provided zero coverage when he tried to refill his prescription. | high |
| 05 | The fixed indemnity plans sold offered coverage like $500 for inpatient surgery and $250 per hospitalization day, compared to an average hospitalization cost of $6,500 per day. Consumers bore the difference entirely. | high |
| 06 | One plan paid only $50 toward physician visits, capped at five visits per year, for an emergency room cap of just $50 per day, one visit per year, while the average out-of-pocket cost for a single physician visit exceeded $360 in 2021. | high |
⚖️ Corporate Accountability Failures
Shell structure, executive liability · 5 points
▼
| 01 | Defendants operated nine interconnected Florida companies sharing the same addresses, officers, employees, vendors, and bank accounts. The shell structure provided legal cover while operating as a single enterprise designed to maximize consumer extraction. | high |
| 02 | Three individual defendants, Tiffanie Gonzalez, Ramzey Hassoun, and Richard Sargent, personally directed all aspects of the scheme and are named individually in the FTC complaint, creating direct executive liability. | high |
| 03 | The FTC complaint was filed under seal and seeks a full asset freeze, appointment of a receiver, and immediate access to the defendants’ business premises, indicating federal authorities view this as an ongoing threat requiring emergency intervention. | high |
| 04 | Downline companies sent commissions from consumer sales back to THO, the parent operation, ensuring that every fraudulent sale enriched the enterprise’s leadership at the top of the pyramid. | med |
| 05 | Defendants violated both the FTC Act and the Telemarketing Sales Rule across three counts: outright misrepresentation, misrepresentation in telemarketing calls, and failure to disclose material limitations before collecting payment. | high |
Timeline of Events
2019
THO opens its first call center and begins targeting consumers searching for ACA health insurance.
2020
The scheme expands. Individual defendants form additional corporate entities to create “downline” telemarketing companies under THO. Consumer harm begins accumulating at scale.
Aug 2024
FTC documents a deceptive Google advertisement from a lead generator site “obamacare-plans.com,” one of many sites defendants paid hundreds of thousands of dollars to purchase leads from.
2024
FTC investigators conduct an undercover purchase transaction with THO agents, recording agents misrepresenting a fixed indemnity plan as a “no-deductible PPO” providing nationwide comprehensive coverage.
Jan 12, 2026
FTC files complaint under seal in the Southern District of Florida seeking permanent injunction, monetary judgment, asset freeze, receiver appointment, and immediate business access.
Direct Quotes from the Legal Record
QUOTE 1
The scope of consumer harm
Core Allegations
“Defendants have caused tens of millions of dollars in harm to consumers.”
💡 The FTC’s own summary of the financial scale of this fraud, covering operations since 2020.
QUOTE 2
The bait-and-switch mechanics
Core Allegations
“In truth, Defendants sell consumers products that provide far less than comprehensive coverage, leaving consumers exposed to owing thousands of dollars in out-of-pocket medical costs.”
💡 This is the core of the fraud: what was sold as protection was actually exposure to catastrophic financial risk.
QUOTE 3
The ER bill no plan covered
Economic Fallout
“The consumer went to an ER because of an allergic reaction and was billed $5,417 because the plan denied coverage. Defendants had actually sold her a fixed indemnity plan bundled with an accident plan and membership association, which at most would have covered $50 for her ER visit.”
💡 A woman who specifically asked for ER coverage was sold a product that covered $50 of a $5,417 emergency bill. This is not a technicality. It is deliberate predation.
QUOTE 4
The life-sustaining medication case
Economic Fallout
“A third consumer specifically asked a Direct Health Solutions agent for a health insurance plan that would cover his $27,000-per-month, life-sustaining medication. Instead, the agent sold the consumer a fixed indemnity plan and membership association that provided no coverage when he later tried to refill his medication.”
💡 Selling someone zero coverage for a life-sustaining medication they explicitly asked about is not a mistake. It is a deliberate choice to take their money and abandon them.
QUOTE 5
The FTC undercover investigation
Core Allegations
“A THO agent specifically discouraged him from enrolling in another marketplace plan, claiming the deductible would be too high. Instead, THO’s agent directed the investigator to a ‘no-deductible PPO’ plan… In reality, the ‘no-deductible PPO’ plan was actually a fixed indemnity plan.”
💡 Recorded proof that agents systematically steered consumers away from real insurance and toward fraudulent products. This is not accidental misdirection. It is trained behavior.
QUOTE 6
The cancellation trap
Corporate Accountability Failures
“In numerous instances, consumers are forced to cancel or freeze their credit cards or file complaints in order to cancel their plans and obtain refunds.”
💡 The trap was designed both ways: easy to enter, nearly impossible to exit. This is a feature, not a bug, of the business model.
Commentary
How could consumers not realize they were buying fake insurance?▼
The scheme was built to exploit exactly this vulnerability. Consumers were actively searching for ACA health insurance and were diverted to websites designed to look like government exchanges. By the time they got on a call, they believed they were speaking with a licensed government-affiliated agent. The agents used real insurance vocabulary, promising PPOs, copays, deductibles, and in-network providers. The fraud was sophisticated, scripted, and deliberate. Blaming consumers for being deceived is blaming the victims of predation.
What is a fixed indemnity plan and why is it not real insurance?▼
A fixed indemnity plan pays a predetermined fixed amount for specific medical events regardless of what the care actually costs. A plan might pay $250 per day of hospitalization while the average cost is $6,500 per day. Comprehensive health insurance pays most of the actual cost and caps what you owe. Fixed indemnity plans transfer no risk to the insurer. They are supplemental products meant to accompany real insurance, not replace it. Selling them as primary coverage is deception by definition.
Who was most harmed by this scheme?▼
The FTC’s complaint describes consumers who were recently unemployed and without job-based coverage, consumers managing serious chronic conditions requiring expensive medications, and families seeking basic ER and primary care coverage. These are people at their most financially and medically vulnerable, actively trying to protect themselves. Defendants targeted the moment of that search and exploited it. People who could least afford catastrophic medical debt were the ones left holding it.
Is this actually a serious case or just a regulatory technicality?▼
This is a serious, large-scale fraud case. The FTC sought an emergency asset freeze and receiver appointment, which courts grant only when there is evidence of substantial ongoing harm and risk of asset dissipation. The complaint covers three separate counts of federal law violations. An undercover federal investigator documented the deception firsthand. Multiple named consumers describe devastating financial outcomes. The complexity of the nine-company shell structure suggests deliberate legal insulation. This is not a paperwork violation.
What can I do to prevent this from happening again?▼
If you are shopping for health insurance, go directly to HealthCare.gov or your state’s official exchange. Do not respond to unsolicited calls about health coverage. If someone calls you claiming to offer ACA plans, ask directly: “Is this plan ACA-compliant? Does it have an out-of-pocket maximum? What is the insurer’s name?” Legitimate plans must answer these questions clearly. Report suspicious health insurance calls to the FTC at ReportFraud.ftc.gov. Support legislation that funds federal telemarketing enforcement and strengthens consumer protections against junk health plans.
Here is a press release from the FTC’s website about this fraud of insurance: https://www.ftc.gov/news-events/news/press-releases/2026/01/ftcs-request-court-halts-operations-deceptive-health-care-telemarketers
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