Business ProfileforGlobal Health Initiative, Inc.

The following describes a pending government action that has been formally brought by a government agency but has not yet been resolved. We are providing a summary of the government's allegations, which have not yet been proven.

Tennessee: On October 9, 2018, United States of America and the United State Attorney for the Eastern District of Tennessee, brought an action against Mr. Andrew Assad, Mr. Peter Bolos, Mr. Michael Palso owners of Synergy Pharmacy Services, Inc., Precision Pharmacy Management, LLC., Mr. Larry E. Smith owner/manager of ALPHA-OMEGA Pharmacy, LLC., Germaine Pharmacy, Inc., ERX Consultants, LLC (D.B.A Zoetic Pharmacy), Tanith Enterprises, LLC (D.B.A. Medvest Management Services) and ULD Wholesale Group, LLC. and other businesses for alleged violations:
Count Two thru Twenty-Three for Mail Fraud
Count Twenty-Four thru Thirty for Mail Fraud
Counts Thirty-One and Thirty-Two for Introduction of Misbranded Drugs into Interstate Commerce with the Intent to Defraud and Mislead
Prescription Brokering,
Inflating Average Wholesale Price Medications,
Co-pay Collection Fraud,
Conspiracy to Commit Health Care Fraud,
Money Laundering
Conspiracy to Commit Mail Fraud.


For more information regarding this case please contact The United States Department of Justice at https://www.justice.gov or number 202-353-1555.
(Case No. 2:18-CR-1 YO, U.S District Court Eastern District of Tennessee at Greeneville).
Tennessee alleges,

From on or about June 1, 2015 through on or about April 1, 2018, the defendants Mr. Assad, Mr. Bolos, Mr. Palso, Synergy Pharmacy Services, Inc., Precision Pharmacy Management, LLC, Mr. Smith, ALPHA-OMEGA Pharmacy, together with HealthRight LLC and Mr. Scott Roix (both of whom are named defendants in separate charging instruments), and other persons and entities known to the grand jury but not charged herein, knowingly and willfully combined, conspired, and agreed to deceive tens of thousands of patients and more than 100 doctors located in the Eastern District of
Tennessee and elsewhere for the purpose of executing a scheme and artifice to defraud healthcare benefit programs, and to obtain by means of false and fraudulent pretenses, representations, and promises, approximately $174,202,105 owned by or under the custody or control of healthcare benefit programs, in connection with the delivery of and payment for health care benefits, items or services, and, in furtherance thereof, caused to be submitted not less than approximately $931,356,936 in fraudulent claims for payment.

On or about July 11,2016, B.H. purchased ALPHA-OMEGA PHARMACY LLC, and was originally located in Largo, Florida and then moved to 4625 East Bay Drive, Suite 313, Clearwater, Florida. Mr. Smith controlled the business and operations of ALPHA-OMEGA, even though it was legally owned by B.H.
On or about July 18, 2017, S.C. purchased Germaine Pharmacy, Inc., and from the date of purchase through the end of the conspiracy GERMAINE was located at 251 I West Swann Avenue, Suite 102, Tampa, Florida and Mr. Smith controlled the business and operations of GERMAINE, even though it was legally owned by S.C
On or about July 18,2017, K.C. purchased ERX CONSULTANTS LLC doing business as Zoetic Pharmacy, a company organized under the laws of the state of Texas and from the date of purchase through the end of the conspiracy Zoetic was located at 10674 Westheimer Road, Houston, Texas and Mr. Smith controlled the business and operations of even though it was legally owned by K.C.

At all times relevant to this indictment Tanith Enterprises, LLC. doing business as Medvest Management Services was a company Mr. Smith owned and controlled the business and used Tanith and its employees to conceal his ownership of, economic and controlling interests in, ALPHA-OMEGA, Germaine, and Zoetic.
From on or about June 2, 2015 through on or about September 1, 2016, ULD Wholesale Group Inc. was a corporation in Louisiana and on or about September 1,2016, ULD Wholesale Group Inc. was administratively terminated by the State of Louisiana and then re-instated on or about March 10,2017.
On or about March 6, 2018, ULD Wholesale Group Inc. was converted into ULD Wholesale Group, LLC, which Mr. Smith owned and controlled the business and operations of ULD Wholesale Group Inc. and ULD Wholesale Group, LLC. which Mr. Smith used ULD Wholesale to purchase Inflated AWP Medications for, and launder money on behalf of, ALPHA-OMEGA, Germaine, and Zoetic, in each case in furtherance of the conspiracy as described herein.
Beginning on or about June 1, 2015 and continuing until on or about April I, 2018, in the Eastern District of Tennessee and elsewhere, the Synergy Principals, Synergy, Precision, Mr. Smith, ALPHA-OMEGA, Germaine, Zoetic, ULD Wholesale, Tanith, HealthRight, Mr. Roix, and other persons and entities known to the grand jury, did knowingly, intentionally, and unlawfully combine, conspire, confederate, and agree with each other to execute and attempt to execute a scheme and artifice to defraud health care benefit programs and to obtain, by means of false and fraudulent pretenses, representations, and promises, any of the money and property owned by, or under the custody or control of, any health care benefit program, in connection with the delivery of or payment for health care benefits, items, or services.

It was part of the conspiracy that the Synergy Principals, Synergy, Precision, Mr. Smith, ALPHA-OMEGA, Germaine, Zoetic, ULD Wholesale, Tanith, HealthRight, Mr. Roix, and other persons and entities known to the grand jury, formulated a plan and agreement that, among other things, included the following:
Prescription Brokering
Inflated Average Wholesale Price Medications
To ensure that the conspiracy was profitable, the Synergy Principals and Mr. Smith purchased dozens of medications at prices substantially below the manufacturer-reported average wholesale prices ("AWP") of those medications, knowing that the PBMs relied on such manufacturer-reported A WPs in calculating how much to pay pharmacies (each an "Inflated AWP Medication").

Mr. Roix deployed HealthRight's care platform to obtain doctor-authorized prescriptions for the highly-profitable Inflated A WP Medications as indicated on the prescription lists provided by the Synergy Principals and Mr. Smith. The care platform consisted of three parts:
Phase I: The HealthRight call center staff obtained each patient's insurance information.
Phase II: A HealthRight employee masquerading as a practicing medical professional in rote fashion transcribed patients' answers to a pre-printed set of questions; then, HealthRight's care platform used the patients' insurance information to select the specific Inflated A WP Medication(s) to be prescribed as well as the pharmacy to fill the prescription, all before HealthRight or the pharmacies presented any information to any doctor.
Phase III: HealthRight emailed or texted a doctor licensed in the patient's state and informed the doctor that an "e-consult" was ready for online review; deceived the doctor to believe that a practicing medical professional had reviewed the patient's medical history by informing the doctor that a nurse spoke with the patient and by presenting the patient's transcribed answers to the pre-printed questions to the doctor; and deceived the doctor to believe that the patient had requested a prescription for a specific Inflated AWP Medication by name - the doctor could then select that exact Inflated AWP Medication from a drop-down menu pre-populated into HealthRight's care platform with the ordered lists provided by the conspiring pharmacy selected in phase II.


In phase I, to obtain prescriptions to sell to the SYNERGY Principal's and Mr. Smith, Mr. Roix and HealthRight deceived patients into providing their health insurance information and accepting Inflated AWP Medications. To accomplish this, Mr. Roix and HealthRight employed one or more of the following techniques with each patient:
Placed fraudulent advertisements on various websites and social media outlets including without limitation Facebook and Yahoo!, indicating that HealthRight offered clinical research trials utilizing cannabidiol oil or CBO oil or other cannabis related medications;
Placed fraudulent advertisements on various websites and social media outlets including without limitation Facebook and Yahoo!, indicating that HealthRight offered clinical stem cell research trials;
Falsely informed patients that they would be notified of the amount of any copay, and have the opportunity to cancel their orders, before medications were mailed to them;
Falsely informed patients that they would receive the medications as part of a free trial program;
Falsely informed patients that they were not required to pay their copays;
Falsely informed patients that the Inflated A WP Medications were very effective at treating various ailments;
Deceived patients about the specific Inflated AWP Medications that would be shipped to them intentionally withheld from patients the price of Inflated AWP Medications ;
Intentionally withheld from patients that the Synergy Principals and Mr. Larry Smith were paying HealthRight for each prescription employed intentionally vague and misleading call scripts to induce patients to say "yes" to certain recorded questions ignored patient requests to discuss prescriptions with the pharmacy or doctor prior to dispensing; and engaged in numerous other deceptive techniques and practices.
Also, in phase I, as part of the conspiracy and at the direction of the Synergy Principals and Mr. Smith, Mr. Roix and HealthRight automatically disqualified patients who did not have health insurance with prescription coverage because the Synergy Principals and Mr. Smith knew they would be unable to sell any Inflated AWP Medications to patients for cash - the entire conspiracy was intended to defraud healthcare benefit programs represented by the PBMs.
Once the phase I caller confirmed that the patient had health insurance with prescription coverage, the phase I caller automatically waived HealthRight's standard patient consultation fee of approximately $55 for every patient contacted by HealthRight about Inflated AWP Medications. HealthRight did this because Mr. Roix and HealthRight knew that the patients would not agree to accept Inflated AWP Medications if they were required to pay any fee to HEALTH RIGHT.
As a result, kickbacks (as described below) from the Synergy Principals, Mr. Smith, and others known to the grand jury, were the only source of revenue to HealthRight for its role in the conspiracy. Through this fraudulent process, Mr. Roix and HealthRight generated enormous artificial demand for Inflated AWP Medications selected by the Synergy Principals and Mr. Smith.
In phase II, Mr. Roix and HealthRight deceived patients into believing that they we're speaking with nurses or other trained clinical staff who were engaged in the practice of medicine by, among other things, causing HealthRight staff members to tell the patients that they were nurses or other trained medical staff when, in fact, HealthRight explicitly instructed all staff members that they were not engaged in the practice of medicine.
At the end of phase II, HealthRight's care platform selected the specific conspiring pharmacy (i.e., Synergy, a Precision Pharmacy, ALPHA-OMEGA, Germaine, Zoetic, or another conspiring pharmacy) that would fill the prescription based solely upon two factors:
The conspiring pharmacy had to have the ability to bill the designated PBM for that patient's prescription (i.e., it could not have been terminated by that PBM for fraud, waste, or abuse, or for any other reason)
The pharmacy was licensed to mail prescriptions to the patient's state.
In phase III, after obtaining patient authorization using the misleading methods described above in phases I and II, Mr. Roix and HealthRight deceived doctors to authorize medically unnecessary prescriptions for Inflated AWP Medications to patients. To accomplish this, Mr. Roix and HealthRight used one or more of the following techniques with each doctor:
Falsely led doctors to believe that nurses were triaging patients before patient information was conveyed to doctors;
Falsely led doctors to believe that patients had requested specific Inflated AWP Medications by name or that patients had requested medications for supplemental therapies for scars, headaches, or general wellness;
Intentionally concealed from doctors information that was material to their decisions to authorize prescriptions for Inflated AWP Medications including, without limitation, the prices that the PBMs would be billed for such Inflated AWP Medications;
Intentionally concealed from doctors that the Synergy Principals and Mr. Larry Smith paid HealthRight on a per-prescription basis or split revenue with HealthRight for each billed prescription authorized by those doctors;
Intentionally concealed from participating doctors the fact that many patients had stated that the Inflated AWP Medications were ineffective at treating patient ailments;
Instructed HealthRight staff to assign "patient encounters" to those doctors who were most likely to authorize prescriptions, as determined by historical performance data within HealthRight's possession and without regard to patients' medical needs;
Designed the care platform in a manner that channeled participating doctors to select Inflated AWP Medications from a drop-down menu that was pre-populated with a list consisting only of Inflated AWP Medications pre-selected by the Synergy Principals and Mr. Smith;
Falsely led doctors to believe that patients had requested 3 automatic refills for prescriptions for Inflated AWP Medications;
Engaged in numerous other deceptive techniques and practices.

After receiving the substitution cascade from the Synergy Principals and Mr. Smith, Mr. Roix and HealthRight induced doctors to authorize the substitution cascade by leading them to believe that by doing so they were authorizing the substitution of therapeutically-equivalent generic drugs for the prescribed Inflated AWP Medication; whereas, in fact, the doctors were authorizing the pharmacies to "phish" or "test bill" until they found the most profitable drug covered by each patient's insurance.
As part of the scheme, Mr. Roix and HealthRight, with the knowledge of the Synergy Principals and Mr. Smith, interfered with the creation of a valid "practitioner "patient relationship by submitting all or substantially all patient consults in electronic or "e-consult" format as opposed to telephonic format. For not less than 950/0 of the prescriptions that HealthRight sold to the Synergy Principals and Mr. Smith, the prescribing doctor never spoke with the patient. The Synergy Principals and Mr. Smith knew that Mr. Roix and HealthRight did this because they understood that if doctors were able to speak freely with patients, the doctors would be far less likely to issue prescriptions for Inflated AWP Medications since the patients did not want the Inflated AWP Medications in the first place.

The Synergy Principals then caused Mr. Roix and HealthRight to append this doctor attestation to thousands of the prescriptions for Inflated AWP Medications that HealthRight obtained through its care platform and sold to the Synergy Principals and Mr. Smith. The Synergy Principals requested these phony doctor attestations so that they could deceive the PBMs into believing that a valid practitioner-patient relationship existed for each prescription for Inflated AWP Medication, even though they knew or had reason to believe that the underlying prescriptions for Inflated AWP Medications were not based upon a valid practitioner-patient relationship, as required by applicable law and the provider agreements.


As described in paragraph above, the PBMs required that pharmacies notify the PBMs of changes in ownership or control. The Synergy Principals and Mr. Smith subverted these requirements by concealing their ownership of, or economic or controlling interests in, various pharmacies. During the conspiracy, various PBMs terminated their contracts with Synergy and ALPHA-OMEGA due to fraud, waste, and abuse committed by those pharmacies.
As a result of these terminations, the Synergy Principals created Precision in October 2016 for the purpose of billing HealthRight prescriptions that Synergy could not bill by re-directing those prescriptions through pharmacies in which the Synergy Principals had concealed ownership, economic, or controlling interests, including pharmacies in Florida, Indiana, and Texas.
On or about July 17, 2017, Mr. Smith installed trusted confederates as the nominal owners of Germaine and Zoetic, but maintained control of the business and operations of both of those pharmacies through Tanoth, which handled almost all of the business and operations of ALPHA-OMEGA, Germaine, and Zoetic. Mr. Smith did this for the purpose of billing HealthRight prescriptions that ALPHA-OMEGA could not bill by re-directing those prescriptions through Germaine and Zoetic.
Prior to the conspiracy, Mr. Smith owned a pharmacy called Oldsmar. Mr. Smith employed D.V. as the pharmacist in charge of Oldsmar. In the early part of2015, Express Scripts and CVS Caremark terminated Oldsmar for violations of their provider agreements. As a result, Mr. Smith concealed his and Tanith's ownership and control in ALPHA-OMEGA, and D.V.'s role as the pharmacist in charge of ALPHA-OMEGA, from the outset of their involvement in the conspiracy that is the subject of this indictment.

As described above, the PBMs required that Synergy, the Precision Pharmacies, ALPHA-OMEGA, Germaine, and Zoetic collect co-pays from their patients. In practice, this meant that the pharmacies had to collect co-payments from tens of thousands of patients whom HealthRight had deceived into providing prescription insurance information, almost all of whom didn't understand they were going to receive Inflated AWP Medications.
The Synergy Principals and Mr. Smith understood that they could not collect co-pays from these deceived patients because the patients did not want the Inflated AWP Medications in the first place. However, the Synergy Principals and Mr. Smith also understood that if the PBMs audited Synergy, the Precision Pharmacies, ALPHA-OMEGA, Germaine, or Zoetic, and discovered that they were not collecting the co-pays, then the PBMs would terminate the pharmacies thereby bringing an abrupt end to the conspiracy.
Accordingly, the Synergy Principals came up with a variety of schemes to launder money through several persons and companies including Global Patient Services LLC, Affordable Medication Solutions LLC, and RxSolutions Inc. to make it appear to the PBMs as though Synergy and the Precision Pharmacies were collecting co-pays when, in fact, they routinely and systematically failed to do so. The Synergy Principals also deceived the PBMs by changing patient names on co-pay receipts and then presenting the falsified co-pay receipts to the PBMs in connection with fraud, waste, and abuse audits conducted by the PBMs.

Similarly, Mr. Smith, Tanith, and ULD Wholesale employed at least one scheme to launder money through a company called AlphaScrip Inc. to make it appear to the PBMs as though ALPHA-OMEGA, Germaine, and Zoetic were collecting co-pays when, in fact, they routinely and systematically failed to do so.
Beginning on or after the early part of2016, the Synergy Principals, on behalf of Synergy, agreed to buy at least 2,600 prescriptions for Inflated AWP Medications per month from HealthRight in exchange for a payment to HealthRight of $300,000 per week, or approximately $500 per prescription.
On or about October 6, 2016, the Synergy Principals organized Precision in the State of Florida for the purpose of concealing the Synergy Principals' ownership of, or economic or controlling interests in, various pharmacies located in Florida, Indiana, and Texas, so that those pharmacies could bill PBMs for prescriptions for Inflated AWP Medications purchased from HealthRight that Synergy could not bill.
On or about October 10, 2016, the Synergy Principals, on behalf of Synergy and Precision, agreed to purchase at least an additional 800 prescriptions for Inflated AWP Medications per month from HealthRight in exchange for an additional payment to HealthRight of $95,000 per week, bringing the total to at least 3,400 prescriptions per month in exchange for a payment of $395,000 per week.

From on or after September 2015 through the end of the conspiracy, the Synergy Principals in fact:
Purchased tens of thousands of prescriptions for Inflated AWP Medications from HealthRight;
Caused Synergy to bill most of those prescriptions to the PBMs and obtained approximately $77,835,482 as a result;
Caused the Precision Pharmacies to bill the remainder of those prescriptions to the PBMs, for which they received approximately $10,749,563 as a result.
Caused Inflated AWP Medications to be mailed to patients throughout the United States including numerous patients in the Eastern District of Tennessee such as those listed in counts Two through Twenty Three of this indictment.
Paid HealthRight kickbacks, directly and indirectly, amounting to approximately $31,935,752 for such prescriptions.

From on or after October 2016 through the end of the conspiracy, Mr. Smith and Tanith in fact:
Purchased thousands of prescriptions for Inflated AWP Medications from HealthRight.
Caused those prescriptions to be billed to the PBMs through ALPHA-OMEGA, Germaine, and Zoetic, and obtained approximately $24,919,254 as a result.
Caused ALPHA-OMEGA, Germaine, and Zoetic to mail those prescriptions to patients throughout the United States including patients in the Eastern District of Tennessee such as those listed in counts Twenty Four through Thirty.
Paid HealthRight kickbacks amounting to approximately $3,551,624 and
Caused ULD Wholesale to pay an additional approximately $1,615,113 to Mr. Roix for such prescriptions.

The Synergy Principals laundered and attempted to launder not less than:
$70,080 through Global Patient Services LLC, from on or about November 17,2015 through on or about September 8, 2016.
$120,670 through Affordable Medication Solutions LLC, from on or about December 5, 2016 through on or about January 5, 2018.
Not less than $87,159 through RxSolutions Inc., from on or about December 15, 2015 through on or about March 15,2018, all for the purpose of deceiving the PBMs by making it appear as though Synergy and the Precision Pharmacies were collecting copays when in fact they routinely and systematically failed to do so.
From on or about March 6, 2017 through on or about January 19, 20 18, Mr. Smith and ULD Wholesale laundered not less than $1,184,401 through AlphaScrip Inc. for the purpose of deceiving the PBMs by making it appear as though ALPHA-OMEGA, Germaine, and Zoetic were collecting copays when in fact they routinely and systematically failed to do so. As a result of the conspiracy described in this Indictment, the defendants the Synergy Principals, Synergy, Precision, Mr. Smith, ALPHA-OMEGA, Germaine, Zoetic, Tanith, and ULD Wholesale, together with HealthRight, Mr. Roix and others known to the grand jury, caused not less than $931,356,936 in fraudulent claims for payment to be submitted to the PBMs, for which the PBMs paid not less than $174,202,105 on behalf of Medicare, TRICARE, Medicaid, FECA, FEHBP, and the Private Carriers.
Pursuant to Health Care Fraud Conspiracy Forfeiture Allegations, upon conviction of an offense in violation Mr. Andrew Assad, Mr. Peter Bolos, Mr. Michael Palso Synergy, Precision, Mr. Larry Smith ALPHA-OMEGA, Germaine, Zoetic, Tanith, and ULD Wholesale, shall forfeit to the United States of America any property, real or personal, that constitutes or is derived, directly or indirectly, from gross proceeds traceable to the commission of the offense. The property to be forfeited includes, but is not limited to the following:
Money Judgment
A personal money judgment in favor of the United States and against:
defendant Mr. Andrew Assad in the amount of $5,927,416;
defendant Mr. Peter Bolos in the amount of$3,203,414;
defendant Mr. Michael Palso in the amount of $5,737~099;
defendant Mr. Larry Smith in the amount of $1 ,532,928;
defendant Synergy in the amount of $77,835,482;
defendant Precision in the amount of$10,749,563;
defendant ALPHA-OMEGA in the amount of$24,061,540;
defendant Germaine in the amount of$1,438,246;
defendant Zoetic in the amount of $2,621,960;
defendant Tanith in the amount of $1,797,377; and
defendant ULD Wholesale in the amount of$19,401,680

which represent the amount of proceeds each of these defendants personally obtained from the offense(s) described above.
If any of the property described above, as a result of any act or omission of
the defendant:
Cannot be located upon the exercise of due diligence,
Has been transferred or sold to, or deposited with, a third party,
Has been placed beyond the jurisdiction of the court,
Has been substantially diminished in value, or
Has been commingled with other property which cannot be divided without difficulty,
The United States of America shall be entitled to forfeiture of substitute property pursuant.

In January 2021 Mr. Larry Everett Smith pleaded guilty to one count of conspiracy to commit health care fraud. In a written plea agreement Mr. Smith agreed to pay restitution of $24,919,254 and forfeit approximately $3,052,215 and faces up to 10 years in jail.
Sentencing has been set for October 25, 2021.

Mr. Larry E. Smith, President of Global Health Initiative, Inc is also listed as: Owner/ President of Z Stat Medical, LLC, Administrative Manager of Tanith Enterprises, LLC and Managing Member of ULD Wholesale Group, LLC

A separate BBB Business Profile for this business is available at:

https://www.bbb.org/us/fl/largo/profile/compounding-pharmacy/tanith-enterprises-llc-0653-90341470

https://www.bbb.org/us/fl/palm-harbor/profile/pharmacy/oldsmar-rx-0653-90216544

https://www.bbb.org/us/fl/pinellas-park/profile/compounding-pharmacy/uld-wholesale-group-llc-0653-90341473