They Called It Insurance. The Government Calls It a $91 Million Fraud.

FTC v. Innovative Partners, LP  |  Case 0:26-cv-60976  |  S.D. Florida  |  Filed April 7, 2026

The Cost That Doesn’t Show on a Balance Sheet

You called because you needed health coverage. You thought you were talking to the government. You gave them your name, your date of birth, your bank card number. You went home believing you were finally protected. Then you got sick.

The FTC complaint documents what happened next: one person paid nearly $3,000 in premiums over a year and received $750 in payouts while accumulating more than $80,000 in medical debt for care the telemarketer had explicitly promised would be covered. Another person, managing a serious disease, stopped taking prescription medications after discovering the drug costs were hundreds of dollars higher than what they had been quoted on the sales call.

Already-insured consumers who were targeted separately received nothing at all in return. They paid because they were told their existing coverage was lapsing. Their payments to the defendants had no effect on their real insurance. They discovered this only after the charges had cleared and the plan auto-renewed.

Legal Receipts: In Their Own Words

These are verbatim excerpts from scripts, internal documents, and court-filed records. They are not paraphrases.

Public Deception: What They Said vs. What Was True

The entire revenue model depended on the gap between the sales pitch and the product. Every major claim made during a sales call was false.

• Claimed: Plans are “state issued” or “state private” and affiliated with the government. Reality: No state plays any role in creating or administering these products. The FTC’s Impersonation Rule, 16 C.F.R. Part 461, exists precisely to prohibit this.
• Claimed: Products are PPO policies with $0 deductibles, covering doctor visits, specialist care, prescriptions, urgent care, and emergency services. Reality: The products provide capped payouts for a narrow menu of services, such as $150 toward an ambulance or $200 for an ER visit, with no out-of-pocket maximum for the consumer.
• Claimed: Agents are “licensed health insurance agents” with access to all top-rated plans nationwide. Reality: Historically, few of the telemarketers were actually licensed to sell health insurance.
• Claimed: Consumers can cancel at any time and receive full refunds within 30 days. Reality: Defendants routinely ignored cancellation requests, auto-renewed charges, and rejected refunds. Many consumers eventually had to cancel their bank cards to stop the billing.

Regulatory Gray Zones: The Loopholes They Rented

The defendants constructed a compliance architecture designed not to operate lawfully but to defeat oversight. They found three specific structural gaps and pushed through all three simultaneously.

• By structuring their products as “self-funded employee health benefit plans” under ERISA, defendants triggered federal preemption of state insurance regulation under 29 U.S.C. § 1144(a). This caused the Georgia Office of Insurance and Safety Fire Commissioner to determine it had no jurisdiction to pursue a consumer’s complaint in December 2024. ERISA was designed to protect workers in genuine employment contexts, not to provide regulatory cover for telemarketing fraud.
• To manufacture the ERISA fig leaf, defendants embedded a “New Limited Partner Joinder Agreement” in enrollees’ online portals post-enrollment. The document purported to obligate consumers to perform “a minimum of five hundred (500) hours of work activity on the internet,” details of which are not defined. Consumers consistently report having no recollection of seeing or signing this document.
• By routing sales through a rotating network of third-party “downline” telemarketing companies, defendants created a structural buffer between themselves and any individual deceptive sales call. They then invoked this buffer publicly, telling the Better Business Bureau they had “no affiliation” with the companies making the calls. In practice, defendants controlled all training materials, approved all sales, received all proceeds, and held unilateral authority to terminate downlines’ contracts.

Profit-Maximization at All Costs: The Math of Deliberate Harm

The financial architecture of the scheme was constructed so that harm to consumers was a structural outcome, not a byproduct.

• The flagship “Elite 6MD” plan charged consumers upwards of $300 per month. The maximum a consumer could ever recover, exhausting every illness-related benefit in the plan, was $850 per year. A consumer paying $300/month for a full year and filing every eligible claim would still be $2,750 worse off than if they had bought nothing at all. (Calculated from source figures: $300 x 12 = $3,600 annual premium minus $850 maximum payout = $2,750 net loss to consumer.)
• Defendants report netting thousands of sales per month. Average monthly “premiums” were $330. The enterprise collected more than $91 million since 2023.
• The controlling principal, Ahmed Ibrahim Shokry, made monthly six-figure purchases from lead generation companies on the corporate credit card. He also funneled millions in corporate funds into a personal shell company, Papyrus Green Investments, which the FTC describes as a personal slush fund.
• The lead generation infrastructure was itself part of the monetized harm pipeline. Between April 2023 and June 2025, defendants spent at least $2.3 million purchasing live transfer leads from MediaAlpha alone. In August 2025, MediaAlpha paid $45 million to settle FTC allegations that it misled millions of consumers seeking health insurance and sold their information to telemarketers who did not offer what was advertised.

Delay as a Corporate Weapon: They Kept Going After Everything

At every stage of regulatory escalation, the defendants continued operating. The pattern in the source material documents a company that treated each enforcement signal as a problem to route around rather than a reason to stop.

• In November 2023, Discover opened an investigation and ultimately rescinded defendants’ access to its card network, citing “questionable activity.” Visa and Mastercard also flagged Innovative Partners through their fraud monitoring programs. At least two merchant processing accounts were terminated. The company found new processors and continued.
• In July 2024, Florida DFS inspectors arrived at the call center. Employees unplugged computers and ended the inspection. In the weeks that followed, supervisors collected all training documents from call center cubicles and shredded them, citing the possibility of an “audit.” The operation continued.
• In June 2025, California’s Insurance Commissioner issued a cease-and-desist order and threatened fines of $5,000 per day of continued violations. In November 2025, Michigan’s Department of Insurance and Financial Services issued a second cease-and-desist. Consumer complaints continued arriving after both orders.
• The FTC filed suit in April 2026. The operation had been running since at least 2023. From the first documented fraud complaints to federal court action represents approximately three years of continued harm.

The Contractor Shield: Who Gets Blamed When It Goes Wrong

The “downline” structure was the defendants’ primary liability deflection mechanism. The FTC complaint documents both the control and the denial operating simultaneously.

• Innovative Partners’ form contract with downlines mandated that all sales be approved by Innovative Partners, all proceeds transmitted to Innovative Partners, all cancellation requests routed through Innovative Partners, and all training and marketing materials submitted to and approved by Innovative Partners. The contract also gave Innovative Partners unilateral authority to terminate downlines with or without cause.
• When consumers complained to the Better Business Bureau, defendants submitted boilerplate responses claiming misrepresentations were attributable to “third-party marketing or lead generation companies” with which they had “no affiliation.” This is directly contradicted by the control provisions of their own standard contract.
• The Shokrys recruited many downline principals from Ahmed’s previous telemarketing company, a now-defunct operation that sold a similar set of healthcare-related products. The downline network was staffed largely by people trained in the same methods from the prior operation.

Societal Impact Mapping

Public Health

The FTC complaint documents direct medical consequences for consumers who discovered they had no real coverage.

Economic Inequality

The scheme specifically targeted people searching for affordable healthcare, a population disproportionately represented by people with lower incomes and people with pre-existing conditions who need coverage most urgently.

• Telemarketing scripts were designed to appeal to consumers told that ACA plans and private insurance were too expensive. The “state private” plan was positioned as the affordable option, specifically targeting price-sensitive shoppers.
• Scripts addressing consumers “on a fixed income” told them that purchasing defendants’ product was necessary to avoid unaffordable emergency bills. This reversed the truth: the product left them exposed to precisely those bills.
• Pre-existing condition exclusions for the first 12 months meant that the people most likely to need immediate coverage, those with ongoing health issues, received zero payouts during the period they most needed protection.
• Average monthly premiums of $330 represented a substantial portion of income for the target demographic. The $91 million in total collections accrued on the backs of people who believed they were finally getting healthcare access.

This Is the System Working as Intended

The defendants did not exploit a system that was failing. They navigated a system that created exactly the conditions they needed.

• ERISA’s preemption clause, designed to protect workers in genuine employment benefit arrangements, was repurposed as a regulatory shield. When Innovative Partners invoked ERISA before Georgia’s insurance regulator in December 2024, the regulator dropped the consumer complaint. Federal law, intended to protect workers, became the tool that protected the fraud from state enforcement.
• The lead generation industry that funneled consumers to defendants was itself already under FTC investigation. MediaAlpha, defendants’ primary lead source at a cost of $2.3 million between 2023 and 2025, settled FTC allegations for $45 million in August 2025. Defendants continued purchasing leads from that same ecosystem throughout the period of documented harm.
• Visa, Mastercard, and Discover all flagged Innovative Partners, but the company simply found new merchant processors and continued. The absence of any mechanism to deny a high-fraud-ratio company access to payment infrastructure across the entire network meant that card network flags functioned as friction, not as barriers.
• Three years elapsed between the documented start of the scheme and federal court action. During that period, state regulators in Florida, Georgia, California, and Michigan each took some action. None stopped the operation. The FTC was the only authority with the jurisdictional reach to pursue the full enterprise.

What a Legitimate Fix Looks Like

Editorial analysis. The following recommendations are grounded in the specific documented failure modes of this case and are presented as the authors’ assessment, not as findings of the source document.

Regulatory Track

• The FTC’s Impersonation Rule (16 C.F.R. Part 461) already prohibits government and business impersonation. Enforcement needs to be resourced at a scale proportionate to the volume of telemarketing fraud operating in the healthcare enrollment ecosystem. A $91 million operation running for three years signals that the deterrence gap is large enough for sustained enterprises to operate profitably.
• Payment networks should be required to share fraud-monitoring flags across the entire system, not just within their own network. A company terminated by Discover for “questionable activity” should trigger review at Visa and Mastercard, not simply a switch to a different processor.
• Lead generation companies that sell consumer data into telemarketing pipelines should bear documented legal liability for the downstream fraud those calls produce when there is evidence the lead generator knew or had reason to know the buyer was engaged in deceptive practices.

Legislative Track

• ERISA’s preemption clause was not designed to shield consumer fraud from state insurance regulators. Congress should clarify that ERISA preemption does not apply to companies that do not maintain genuine employment relationships and that use sham “partnership” structures to manufacture ERISA standing. The specific mechanism used here, affixing consumer electronic signatures to “partner joinder agreements” they never consented to, should be explicitly addressed.
• Federal law should establish a cross-network merchant termination registry accessible to all payment processors, so that companies terminated for fraud-related reasons cannot simply move to the next acquirer and continue operating. This requires legislative authorization for the sharing of commercially sensitive termination data.
• The sale of health-related financial products to consumers requires minimum disclosure standards that apply regardless of whether the product is structured as insurance, a benefit plan, a discount plan, or a partnership arrangement. The current fragmented structure allows products to fall between regulatory categories and avoid substantive consumer protection obligations.

Corporate Governance Track

• Any company collecting monthly recurring payments for health-related products should be required to demonstrate to a payment processor that its sales scripts have been reviewed and approved by a licensed compliance attorney, and that compliance review records are maintained and producible to regulators.
• The use of a shell company as a personal fund while operating a consumer-facing subscription business, as documented here with Papyrus Green Investments, should trigger automatic personal liability for the individuals directing those transfers in any subsequent FTC enforcement action.
• Companies that contract with third-party telemarketing firms should be legally responsible for those firms’ conduct when they exercise the level of control documented here: script approval, sales approval, training provision, proceeds collection, and unilateral termination authority.

What Now?

Direct accountability in this case runs to Ahmed Ibrahim Shokry (controlling principal, 100% owner of Innovative Partners), Amani Ibrahim Shokry (CTO, call center director), and the four corporate defendants: Innovative Partners LP, American Collective LP, Health Plan Administrators LLC, and Papyrus Green Investments LLC. A federal receiver, Paul O. Lopez of Tripp Scott P.A., has been appointed by the court and has authority over all company assets.

• Watchlist: The FTC is the primary enforcement agency. Case No. 0:26-cv-60976, S.D. Florida. FTC Midwest Region attorneys: mschiltz@ftc.gov and whodor@ftc.gov. File consumer complaints at reportfraud.ftc.gov.
• Watchlist: The California Department of Insurance (CDI) issued a cease-and-desist in June 2025. The Michigan Department of Insurance and Financial Services (DIFS) issued a second in November 2025. Both agencies retain interest in the case.
• If you paid a company calling itself Innovative Health Plan, ACLP Health Plan, or Healthcare Plan, contact the FTC receiver directly. The court order requires the receiver to protect consumers’ interests and prohibits the receiver from collecting consumer debts resulting from the deceptive practices.
• Mutual aid: health justice organizations in your area can help identify legitimate ACA marketplace enrollment assistance. Healthcare.gov open enrollment assistance is free. No legitimate government-connected health plan requires immediate payment over the phone to avoid cancellation of existing coverage.
• If a telemarketer claims your existing insurance will be canceled unless you pay immediately: hang up. Call the number on the back of your insurance card to verify your coverage status directly.