UJI 14-4414. Medicaid fraud; executing plan or conspiracy to execute plan to defraud state or federal health care plan by deceptive marketing.

For you to find the defendant guilty of Medicaid fraud as charged in Count ____, the State must prove to your satisfaction beyond a reasonable doubt each of the following elements of the crime: 1. The defendant [executed] [conspired to execute2]1 a plan or action to defraud a state or federally funded or mandated managed health care plan in connection with the delivery of or payment for health care benefits. 2. [The defendant’s plan included engaging in any intentionally deceptive marketing practice in connection with [proposing] [offering] [selling] [soliciting] [providing]1 any health care service in a state or federally funded or mandated managed health care plan].3 3. This happened in New Mexico on or about the __________ day of ______________, __________.4