People v. Allen, 295 Mich. App. 277

Allen pled guilty to attempting to commit prescription fraud under MCL 333.7407(l)(c); MCL 333.7407a(l).
The trial court sentenced her under a sentencing agreement to one year of probation and ordered restitution of $5,753.88 to Blue Cross Blue Shield of Michigan.
Allen used a fraudulent prescription that contained a legitimate Blue Cross contract number; the pharmacy alerted BCBS to the attempted purchase.
Allen, as a vendor employee, had access to Blue Cross subscriber databases containing highly sensitive information.
Burnett, BCBS field investigator, testified the investigation cost $5,738 and was longer and more complex because of Allen’s access to confidential information; the cost was calculated by 44 hours at $130.77 per hour.
BCBS argued the investigation represents a direct financial loss because the time could have been spent on other claims or controlling premiums; the trial court agreed and ordered restitution.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether BCBS suffered a loss under CVRA from Allen's conduct.	Allen contends there was no loss; costs would have been incurred regardless.	Allen argues no direct financial harm from the crime.	No clear error; BCBS suffered a direct financial loss from the time spent investigating.

People v. Gahan, 456 Mich 264 (1997) (restitution requires full compensation to victims; statutory interpretation applied de novo)
People v. Akins, 259 Mich App 545 (2003) (standard for reviewing restitution findings; clear error standard)
People v. Bemer, 286 Mich App 26 (2009) (statutory interpretation of restitution under CVRA)
People v. Gubachy, 272 Mich App 706 (2006) (broad construction of 'course of conduct' and remedial nature of CVRA)