UJI 14-4415. Medicaid fraud; executing plan or conspiracy to execute plan for delivery or payment of benefits by fraud or fraudulent representation.

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 obtain by false or fraudulent representation4 or promise, _______________3, which is anything of value, in connection with the delivery of or payment for health care benefits. 2. The health care benefits were in whole or in part, [paid for] [reimbursed] [subsidized]1 by a state or federally funded or mandated managed health care plan. 3. This happened in New Mexico on or about the __________ day of ______________, __________.5