Petrick

I. BACKGROUND3

1 Stars is a California corporation that provides therapy and counseling services to children. 2 Dkt. No. 27 ¶ 6. Stars bills patients and receives payment through both private insurance 3 companies and federal and state government-funded insurance programs, including Medicaid and 4 Medi-Cal. Id. 5 Ms. Petrick worked as a Board Certified Behavioral Analyst (“BCBA”) at Stars beginning 6 in October 2017. Id. ¶ 14. At some point, Stars promoted Ms. Petrick to Director of Operations. 7 Id. In that role, Ms. Petrick was required to “maintain accurate documentation of billable tasks 8 that meets the requirements of regulatory agencies and funding sources.” Id. ¶ 17. Using a 9 software program called Central Reach, Ms. Petrick had access to reports of services provided to 10 patients and corresponding billing codes. Id. ¶ 16. The Stars billing department used reports 11 generated from Central Reach to request payment from government-funded insurance programs 12 and from private insurance companies. Id. ¶ 18. 13 In reviewing Central Reach reports, Ms. Petrick observed that Stars employees known as 14 “leads” billed for certain services that only BCBAs could…