The same action can break multiple laws. Unlawful discharge of a firearm is a crime, but it can also kill someone and thus break a different law. https://www.azleg.gov/ars/13/03107.htm

Here we don’t know which specific laws were broken because we lack details, but the companies definitely signed a contract agreeing to commit fraud.

Anyway, the comment I responded to had “require an intention to harm to a victim” it’s that aspect I was addressing. My point was the transmission of information itself can be harmful to someone other than the recipient of that information. So the same act fulfills both aspects of fraud (deception + criminal intent), and also breaks some other law.

It depends on the context. I’ve gathered evidence to support prosecution of an individual disclosing PHI who was doing so to facilitate criminal acts.