In August 1991, the HHS Office of the Inspector General ("OIG") initiated an investigation of
Caremark's predecessor. Caremark's predecessor was served with a subpoena requiring the
production of documents, including contracts between Caremark's predecessor and physicians
(Quality Service Agreements ("QSAs")). Under the QSAs, Caremark's predecessor appears to have
paid physicians fees for monitoring patients under Caremark's predecessor's care, including
Medicare and Medicaid recipients. Sometimes apparently those monitoring patients were referring
physicians, which raised ARPL concerns