In March 2020, as the COVID-19 pandemic was first beginning to take hold, the New York State Department of Financial Services (DFS) issued a report on insurance fraud that highlighted the fact that suspected no-fault automobile insurance fraud accounted for 59% of the 25,985 insurance fraud reports that the DFS's Insurance Frauds Bureau received in 2019—a 6% increase over the prior year. Perhaps more ominously, suspected no-fault insurance fraud accounted for 89% of all health care fraud reports the Bureau received that year. See DFS, "Investigating and Combating Health Insurance Fraud" (the DFS Report).