WellCare, Tenet Have More Than Probes in Common

WellCare, too, expressed a "strong commitment" to its compliance program when questioned for this story. Moreover, the company said that it has actually enhanced that program with new marketing safeguards in recent months.

Otherwise, however, WellCare has said very little -- even canceling the question-and-answer segment of this month's quarterly conference call -- since the late-October raid on its headquarters.

Still, WellCare has loudly promoted "The Trust Program" in the past. This spring, in fact, WellCare issued a press release reminding investors that its Trust program was "designed to ensure full compliance with applicable laws and regulations (and) to establish a culture of integrity and trust" within the company. In both that press release and another that soon followed, Bereday personally promised that WellCare has "zero tolerance" for wrongdoing.

WellCare takes a similarly tough stand in guidelines issued to employees.

"The Trust Program, federal and state laws and WellCare's high standards of business ethics will be enforced, suspected violations will be investigated and violations will be corrected all in a fair manner -- regardless of the suspected violator's position within WellCare," the company guidelines state. "It is essential that WellCare engage in an active program of preventing, detecting and reporting all suspected incidents of fraud or abuse.

"When in doubt, WellCare directors, associates and business partners are encouraged to seek guidance from the chief compliance officer or his designee."