Regulatory Liability – The False Claims Act in Numbers
These figures reflect cases brought under the False Claims Act and settled between January 2009 and July 2017, where defendants were healthcare related companies and individuals including hospital systems, manufacturers of healthcare products, ambulatory services and laboratories

The Cardondelet Health Network

Date of settlement: 2014

Settlement amount: $35M

Description: The settlement said Carondelet St. Mary’s and Carondelet St. Joseph’s hospitals in Tucson were accused of submitting false bills to Medicare, to the Federal Employees Health Benefit Program and to the Arizona Health Care Cost Containment System, the state’s Medicaid program. The claims were for inpatient rehabilitation services billed between April 2004 and December 2011, court documents show.

Link: http://tucson.com/news/business/carondelet-pays-m-to-settle-false-claim-allegations/article_28e4ddfe-513d-5417-9fd6-b67b6e42336a.html

Cardiovascular and Thoracic Surgeons of Nevada Inc.

Date of settlement: 04/30/18

Settlement amount: $1.5M

Description: According to the government, CTS, whose principal physician is Dr. Bashir Chowdhry, allegedly billed the programs for services it never actually rendered to cardiac patients, and also billed for certain surgical, evaluation and management services that were more expensive than what the facility actually provided.

Link: https://www.law360.com/health/articles/1038561/nev-surgery-practice-pays-1-5m-to-end-fca-allegations

Hospice of Arizona L.C., along with a related entity, American Hospice Management LLC, and their parent corporation, American Hospice Management Holdings LLC

Date of settlement: 03/20/13

Settlement amount: $12M

Description: : The government alleged that Hospice of Arizona and its related entities, engaged in certain practices that resulted in the admission of ineligible patients or inflated bills, including pressuring staff to find more patients eligible for Medicare, adopting procedures that delayed and discouraged staff from discharging patients from hospice when they were no longer appropriate for such services, and not implementing an adequate compliance program that might have addressed these problems.

Link: https://www.justice.gov/opa/pr/hospice-arizona-and-related-entities-pay-12-million-resolve-false-claims-act-allegations

Life Care Centers of America Inc.

Date of settlement: 10/24/16

Settlement amount: $145M

Description: The United States alleged in its complaint that Life Care instituted corporate-wide policies and practices designed to place as many beneficiaries in the Ultra High reimbursement level irrespective of the clinical needs of the patients, resulting in the provision of unreasonable and unnecessary therapy to many beneficiaries. Life Care also sought to keep patients longer than was necessary in order to continue billing for rehabilitation therapy, even after the treating therapists felt that therapy should be discontinued.

Link: https://www.justice.gov/opa/pr/life-care-centers-america-inc-agrees-pay-145-million-resolve-false-claims-act-allegations

LHC Group, Inc. (home healthcare company)

Date of settlement: 09/30/11

Settlement amount: $65M plus interest

Description: The government alleges between 2006 and 2008, LHC improperly billed for services that were not medically necessary and for services rendered to patients who were not homebound

Link: https://www.justice.gov/opa/pr/louisiana-based-lhc-group-inc-agrees-pay-us-65-million-resolve-false-claims-act-allegations

Sabine Optical Laboratories, Inc.

Date of settlement: 11/25/13

Settlement amount: $1.2M

Description: Government alleged that from August 2005 through April 30, 2012, the laboratory violated the Federal and State False Claims Acts (and unlawfully enriched themselves) by improperly billing Medicaid for services performed by an unauthorized provider using the Medicaid provider number of another provider, for adjustment and dispensing services that were never performed, for worthless services due to an excessive number of Medicaid patients being seen in one day, and for lenses that were never made.

Link: https://www.justice.gov/usao-mdla/pr/sabine-settlement

Extraordinary Care Network and Barbara Sadler and Sedric Blakes (Home Health Services)

Date of settlement: 06/02/16

Settlement amount: $1.2M and owner and CFO of company sentenced to 44 months in federal prison

Description: Defendants admitted that they engaged in a multi-year scheme to defraud Medicaid, through the health care company that they owned and operated. SADLER admitted that she and others submitted fraudulent claims to Medicaid in which they falsely represented that Extraordinary Care had provided one-on-one attendant care services, when in fact such services had not been provided as represented. In furtherance of the scheme, SADLER admitted that she and her co-conspirators would fabricate progress notes, forge the signatures of unwitting company employees, and then use such documents as support for fraudulent claims to Medicaid for reimbursement.

Link: https://www.justice.gov/usao-mdla/pr/owner-and-chief-financial-officer-healthcare-company-sentenced-prison-their-roles-fraud

Fredericksburg Hospitalist Group, P.C

Date of settlement: 06/02/17

Settlement amount: $4.2M

Description: The whistleblower complaint, which was originally filed under seal, alleged that FHG and its member hospitalists knowingly and intentionally upcoded evaluation and management (E&M) codes to the highest code levels in billing Medicare and other federal healthcare payors in connection with their providing hospitalist services to patients at Mary Washington Hospital and Stafford Hospital. After an investigation into the matter, the United States alleged that from January 2010 through April 2015, the defendants knowingly and intentionally increased the level of E&M codes to the highest code levels, resulting in increased reimbursement amounts paid by the federal healthcare payors to the billing defendants.

Link: https://www.justice.gov/usao-edva/pr/fredericksburg-hospitalist-group-pays-42-million-settle-civil-fraud-case

Fairfax Nursing Center

Date of settlement: 02/13/13

Settlement amount: $700,000

Description: The settlement resolves claims that FNC provided excessive, medically unnecessary, or otherwise non-reimbursable physical, occupational, and speech therapy services to 37 Medicare beneficiaries serviced by FNC between January 2007 and December 2010. The United States alleged that the rehabilitation therapy services provided by FNC to these beneficiaries were not reasonable and necessary for the treatment of their condition. Specifically, the United States alleged that the therapy services were often excessive, duplicative, performed without clear goals or direction, and, in some instances, performed primarily to capture higher reimbursement rates.

Link: https://www.justice.gov/usao-edva/pr/fairfax-nursing-center-pay-700000-resolve-false-claims-act-allegations

Medical Transport LLC

Date of settlement: Medical Transport LLC

Settlement amount: $9M

Description: The government alleged that Medical Transport submitted false or fraudulent claims to Medicare, Medicaid, and TRICARE for ambulance transports that were not medically necessary, that did not qualify as Specialty Care Transports, and that were billed improperly to the federal health care programs when they should have been billed to other payers.

Link: https://media.defense.gov/2018/Mar/29/2001896649/-1/-1/1/AMBULANCE-COMPANY-PAY-9-MILLION-.PDF

Holiday Acquisition Corp. and Fortress Investment Group, LLC

Date of settlement: 2016

Settlement amount: $8.9M FCA Settlement

Description: The named defendants allegedly knowingly assisted veterans or their surviving spouses in completing and submitting false claims for veteran’s benefits under the Aid and Attendance and Housebound Benefits program.

Link: https://www.justice.gov/usao-or/pr/united-states-recovers-over-8-million-false-claims-act-settlements-fraud-against-va-and

20/20 Eye Clinic

Date of settlement: 2017

Settlement amount: $1.7M FCA settlement and one year in prison

Description: The non-physician defendant and his father, Dr. Neal, allegedly routinely subjected many of their patients to medically unnecessary diagnostic tests and fraudulently billed insurance plans for these services.

Link: https://www.justice.gov/usao-or/pr/gresham-medical-practice-manager-sentenced-prison-false-billing-and-tax-fraud

Kaiser Northwest Region Hospice

Date of settlement: 2009

Settlement amount: $1.83M FCA settlement

Description: Kaiser NW billed Medicare for hospice services that had allegedly been provided by the Kaiser Northwest Region Hospice without obtaining written certifications of terminal illness required under the federal health care program.

Link: https://www.justice.gov/opa/pr/oregon-hospice-pays-us-183-million-settle-false-claims-act-liability

Visiting Physicians Association

Date of settlement: 2009

Settlement amount: $9.5M FCA settlement

Description: Visiting Physicians Association allegedly submitted claims to the Medicare, TRICARE and Michigan Medicaid for unnecessary home visits and care plan oversight services, for unnecessary tests and procedures, and for more complex evaluation and management services than the services that Visiting Physicians Association actually provided.

Link: https://www.justice.gov/opa/pr/visiting-physicians-association-pay-95-million-resolve-false-claims-act-allegations

Allegiance Health d/b/a W.A. Foote Memorial Hospital

Date of settlement: 2013

Settlement amount: $4M False Claims Act

Description: Allegedly knowingly billed Medicare, Medicaid, and other federal health care programs for medically unnecessary cardiovascular procedures and tests.

Link: https://www.natlawreview.com/article/michigan-cardiology-settlement-medicare-and-medicaid-fraud-allegations

Evercare Hospice and Palliative Care

Date of settlement: 2016

Settlement amount: $18M FCA Settlement

Description: Qui tam settlement for allegations that Medicare reimbursements were claimed for hospice care for patients who were not eligible for such care because they were not terminally ill.

Link: https://www.justice.gov/opa/pr/minnesota-based-hospice-provider-pay-18-million-alleged-false-claims-medicare-patients-who

Complementary Support Services

Date of settlement: 2017

Settlement amount: $4.5M FCA settlement

Description: Allegedly billed Medicaid for claims while knowingly violating clinical supervision requirements.

Link: https://www.justice.gov/usao-mn/pr/minnesota-mental-health-nonprofit-and-its-leaders-pay-45-million-resolve-fraud

HealthEast Care System

Date of settlement: 2009

Settlement amount: $2.28M FCA Settlement

Description: Allegations of overcharging Medicare for performing kyphoplasty procedures.

Link: https://www.justice.gov/opa/pr/minnesota-hospitals-pay-us-228-million-settle-false-claims-act-allegations

Prestige Healthcare

Date of settlement: 2017

Settlement amount: $1M FCA Settlement

Description: Alleged failure to ensure that physician orders were obtained for genetic testing prior and failure to ensure that patients were appropriately informed of the testing and provided with the opportunity to decline the testing.

Link: https://www.justice.gov/usao-wdwi/pr/prestige-healthcare-agrees-pay-nearly-1-million-role-alleged-false-billing-genetic

Odyssey Healthcare

Date of settlement: 2012

Settlement amount: $25M FCA Settlement

Description: Odyssey allegedly submitted false claims to the Medicare program for continuous home care services that were unnecessary or that were not performed in accordance with Medicare requirements.

Link: https://www.justice.gov/opa/pr/hospice-provider-odyssey-healthcare-agrees-pay-25-million-resolve-false-claims-act

South Bay Mental Health Center, Inc.

Date of settlement: 2/8/18

Settlement amount: $4M

Description: MFCA settlement for allegations that it fraudulently billed the state’s Medicaid Program, known as MassHealth, for mental health care services provided to patients by unlicensed, unqualified, and unsupervised staff members at clinics across the state.

Link: https://www.mass.gov/news/mental-health-center-to-pay-4-million-under-ag-settlement-for-illegally-billing-masshealth-for

Centrus Premium Home Care Inc.

Date of settlement: 12/5/17

Settlement amount: $14.2M

Description: MFCA settlement to resolve allegations that a home healthcare provider improperly submitted and received overpayments for services from the state’s Medicaid program, known as MassHealth.

Link: https://www.mass.gov/news/ag-secures-more-than-14-million-from-home-health-agency

Wingate Healthcare, Inc.

Date of settlement: 1/9/16

Settlement amount: $3.9M

Description: Wingate Healthcare, Inc. (Wingate) which owns and manages 16 Skilled Nursing Facilities in Massachusetts and New York (list of locations ), has agreed to settle a False Claims Act (FCA), “qui tam” lawsuit alleging Medicare billing fraud in causing SNF customers to bill for unreasonable and unnecessary rehabilitation therapy.

Link: https://www.jeffreynewmanlaw.com/skilled-nursing-facility-medicare-billing-fraud-3-9-million-sett.html

Pennsylvania Health System

Date of settlement: 1/20/17

Settlement amount: $845K

Description: The agreement settles allegations that UPHS improperly billed Medicare for stent procedures performed by two cardiologists at Pennsylvania Hospital in Philadelphia between 2008 and 2012.

Link: https://www.beckershospitalreview.com/legal-regulatory-issues/penn-health-system-settles-improper-billing-allegations-for-845k.html

Westfield Hospital

Date of settlement: 8/17/16

Settlement amount: $690K

Description: In the qui tam complaint, the whistleblower alleged that the defendants submitted claims to the federal government to receive reimbursement for services performed by non-physicians as “incident to” the services of supervising physicians when, in fact, supervising physicians were away from the office or otherwise incapable of supervising.

Link: https://www.justice.gov/usao-edpa/pr/doctors-and-medical-facilities-lehigh-valley-pay-690441-resolve-healthcare-fraud

West Penn Allegheny Health System

Date of settlement: 3/19/14

Settlement amount: $1.5M

Description: West Penn Allegheny evolved after it was revealed that the hospital chain was renting office space to private physicians at rates well below fair market value. Interestingly, West Penn self-reported the arrangement to authorities at the U.S. Attorney’s Office, prompting an investigation into the propriety of the arrangement.

Link: https://www.justice.gov/usao-wdpa/pr/15m-settlement-west-penn-allegheny-health-system-resolves-false-claims-act-allegations

Vericare Management Inc

Date of settlement: 10/29/15

Settlement amount: $1M

Description: This behavioral health services provider agreed to pay more than $1 million to resolve allegations that it violated the False Claims Act by falsely billing federal health care programs for services that were not medically necessary.

Link: https://www.justice.gov/usao-nj/pr/behavioral-health-services-provider-agrees-pay-1-million-allegedly-submitting-false

Trinitas Regional Medical Center

Date of settlement: 11/18/09

Settlement amount: $3M

Description: Alleged that the hospital fraudulently inflated their charges to Medicare patients to obtain enhanced reimbursement from Medicare.

Link: https://www.justice.gov/opa/pr/new-jersey-hospital-pay-3-million-resolve-allegations-medicare-fraud

Cooper Health System

Date of settlement: 1/24/13

Settlement amount: $12.5M

Description: The Cooper Health System has agreed with the U.S. Attorney’s Office for the District of New Jersey and the State of New Jersey to pay $12.6 million to settle allegations that it violated the federal False Claims Act and New Jersey False Claims Act by making improper payments to physicians under so-called “consulting” and “compensation” agreements as it sought to build its cardiology program.

Link: https://www.justice.gov/usao-nj/pr/major-new-jersey-hospital-pays-125-million-resolve-kickback-allegations

Sea Mar Community Health Centers

Date of settlement: 1/16/15

Settlement amount: $3.65M

Description: Attorney General Bob Ferguson said the 2½-year investigation revealed the health-care provider overbilled Medicaid for thousands of dental appointments.

Link: https://www.seattletimes.com/seattle-news/sea-mar-to-pay-365m-to-settle-probe-into-medicaid-billings/

Bates Drug Stores

Date of settlement: 3/27/12

Settlement amount: $600K

Description: Bates dispensed drug units which were billed to and paid for by Medicare and Medicaid. Those unused drug units, however, were later returned to Bates and re-dispensed and re-billed to Medicare and Medicaid. The United States and the States of Washington allege that Bates did not follow the Medicare and Medicaid billing requirements and "double-billed" for the same drugs, resulting in false claims being submitted to Medicare and Medicaid.

Link: https://www.justice.gov/archive/usao/wae/news/2012/2012_03_27_Bates_Pharmacy.html

University of Washington

Date of settlement: 4/30/04

Settlement amount: $35M

Description: Mark Erickson, then a compliance officer at the UW, accused the school of massive overbilling in the 1999 lawsuit. The case led to felony pleas by two leading UW doctors, one of whom left his job.

Link: http://community.seattletimes.nwsource.com/archive/?date=20040430&slug=uwmed30

Sound Inpatient Physicians

Date of settlement: 2013

Settlement amount: $14.5M

Description: Hospitalist paid $14.5M overbilling case.

Link: https://www.justice.gov/opa/pr/tacoma-wash-medical-firm-pay-145-million-settle-overbilling-allegations

Physicians Clinic of Spokane

Date of settlement: 2010

Settlement amount: $656,000

Description: Overcharging Medicare for certain blood and cholesterol tests without medical necessity.

Link: https://www.justice.gov/archive/usao/wae/news/2010/2010_06_08_Physicians_Clinic_Settlement.html

Charlotte-Mecklenburg Hospital Authority, dba Carolinas Healthcare System (CHS)

Date of settlement: 6/30/17

Settlement amount: $6.5m

Description: Violations of the FCA by “up-coding” claims for urine drug tests in order to receive higher payment. According to court documents, from 2011 to 2015, CHS conducted urine drug tests, categorized as “moderate complexity” tests by the Food and Drug Administration (FDA), but submitted claims that indicated the company had conducted “high complexity” tests. Claims submitted to federal health care programs include a code that identifies the services provided and that triggers a certain payment. The government alleged that CHS engaged in a practice referred to as “up-coding,” by submitting claims using code G0431, which should be used only for tests classified as “high complexity” by the FDA, instead of using code G0434, which is the code for moderately complexity tests, which triggers a payment of approximately $20.00. As a result of CHS’s up-coding practices, the government alleges that federal health care programs paid CHS, and certain facilities under contract with CHS, approximately $80 more per test for the claims submitted with the higher paying code.

Link: https://www.justice.gov/usao-wdnc/pr/carolina-healthcare-system-agreems-pay-65-million-settle-false-claims-act-allegations

Duke University Health System

Date of settlement: 3/21/14

Settlement amount: $1m

Description: Duke University Health System allegedly made false claims to Medicare, Medicaid, and TRICARE by (1) billing the government for services provided by physician assistants (PA’s) during coronary artery bypass surgeries when the PA’s were acting as surgical assistants (along with graduate medical trainees), which is not allowed under government regulations and (2) increasing billing by unbundling claims when the unbundling was not appropriate, specifically in connection with cardiac and anesthesia services.

Link: https://www.justice.gov/usao-ednc/pr/duke-university-health-system-inc-agrees-pay-1-million-alleged-false-claims-submitted

EmCare, Inc

Date of settlement: 12/19/17

Settlement amount: $29.8m

Description: 2008 to 2012, EmCare received remuneration from non-defunct Health Management Associates (HMA) to increase Medicare admissions at HMA Hospitals by recommending admission for patients whose medical care should have been billed as outpatient or observation services. These recommendations allegedly caused the medically unnecessary admission of Medicare beneficiaries.

Link: https://www.justice.gov/usao-wdnc/pr/emcare-inc-pay-298-million-resolve-false-claims-act-allegations

Infirmary Health System and Diagnostic Physicians Group P.C.

Date of settlement: 7/21/14

Settlement amount: $24.5M

Description: The government’s suit alleged that two IHS affiliated clinics -- IMC-Diagnostic and Medical Clinic, in Mobile, and IMC-Northside Clinic, in Saraland, Alabama -- had agreements with DPG to pay the group a percentage of Medicare payments for tests and procedures referred by DPG physicians, in violation of the Physician Self-Referral Law (commonly known as the Stark Law) and the Anti-Kickback Statute. Also named in the lawsuit was Infirmary Medical Clinics P.C. (IMC), an affiliate of IHS that directly owns and operates approximately 30 clinics in the Mobile area, including the two clinics involved in this lawsuit.

Link: https://www.justice.gov/opa/pr/alabama-hospital-system-and-physician-group-agree-pay-245-million-settle-lawsuit-alleging

Coastal Neurological Institute, P.C.

Date of settlement: 6/22/17

Settlement amount: $1.4m

Description: Local physician and local neurosurgeon physician group, collectively paid $1.4 million to resolve allegations that they violated the False Claims Act (“FCA”) by engaging in fraudulent schemes to maximize payment from the Medicare, Medicaid, and TRICARE health care programs. The United States alleged that the Defendants knowingly billed federal health care programs for medically unreasonable and unnecessary ultrasound guidance used with routine lab blood draws, and with Botox and trigger point injections. The United States further alleged that CNI, Crumb, and other CNI physician employees unnamed in the lawsuit, knowingly manipulated billing codes in order to circumvent safeguards implemented by Medicare’s National Correct Coding Initiative to combat improper and fraudulent duplicate claim line billing of certain procedure codes, including ultrasound guidance used with needle placement. As a result of this billing scheme, the Defendants sometimes billed 15 to 30 identical ultrasound guidance claims for a single patient office visit.

Link: https://www.justice.gov/usao-sdal/pr/local-physician-dr-james-m-crumb-and-mobile-based-physician-group-coastal-neurological

AnMed Health

Date of settlement: 9/27/17

Settlement amount: $7m

Description: Allegations that AnMed Health knowingly disregarded the statutory conditions for submitting claims to the Medicare program for a variety of services, including radiation oncology services, emergency department services, and clinic services. Specifically, the United States alleged that AnMed Health billed for radiation oncology services for Medicare patients when a qualified practitioner was not immediately available to provide assistance and direction throughout the radiation procedure, as required by Medicare regulations. The settlement also resolves allegations that AnMed Health systematically billed a minor care clinic as if it was an Emergency Department, and billed Emergency Department services as if they were provided by a physician when, in fact, the services were rendered by mid-level providers. Each of these billing practices resulted in higher reimbursements to AnMed Health.

Link: https://www.justice.gov/usao-sc/pr/anmed-health-agrees-pay-7-million-settle-false-claims-act-allegations

Family Medicine Centers of South Carolina

Date of settlement: 9/12/17

Settlement amount: $2m

Description: A South Carolina family medical practice chain, along with its owner and laboratory director, agreed to pay roughly $2 Million to settle charges of violating the False Claims Act and Stark Law which prohibits physician self-referrals. Specifically, Family Medicine Centers of South Carolina (FMC) agreed to pay $1.56 million, and FMC’s principal owner Dr. Stephen F. Serbin and former Laboratory Director Victoria Serbin agreed to pay $443,000.

Link: https://constantinecannon.com/whistleblower/family-medicine-centers-settles-whistleblower-false-claims-act-charges/#.WuylZWeWzcs

Techota, LLC

Date of settlement: 2015

Settlement amount: $150,000

Description: A home healthcare operation providing service to patients in rural Alabama recently settled a whistleblower lawsuit, agreeing to pay the United States government $150,000 to resolve claims that it violated the federal False Claims Act. Techota allegedly submitted false reimbursement claims to Medicare for the home healthcare services of multiple patients who were not home-bound.

Link: https://www.bergermontague.com/blog/index.php/home-healthcare-firm-settles-false-claims-act-lawsuit-for-150000/

Jackson-Madison County General Hospital

Date of settlement: 5/7/15

Settlement amount: $1.32m

Description: Jackson-Madison County General Hospital has paid the United States $1,328,465 to resolve allegations that it billed Medicare and Medicaid in connection with the placement of unnecessary cardiac stents and other unnecessary cardiac procedures.

Link: https://www.justice.gov/usao-wdtn/pr/tennessee-hospital-pays-132-million-settle-allegations-improper-medicare-and-medicaid

Regional Hospital of Jackson

Date of settlement: 7/15/15

Settlement amount: $510k

Description: Regional Hospital of Jackson (Tenn.) has agreed to pay the federal government $510,000 to resolve allegations it violated the False Claims Act by billing Medicare and Medicaid for unnecessary cardiac procedures over an eight-year period, according to the Department of Justice.

Link: https://www.beckershospitalreview.com/legal-regulatory-issues/tennessee-hospital-settles-false-claims-allegations-for-510k.html

Chemed Corp and Vitas Hospice Services

Date of settlement: 2017

Settlement amount: $75M

Description: $75M FCA settlement for knowingly submitting or causing to be submitted false claims to Medicare for services to hospice patients who were not terminally ill.

Link: https://www.justice.gov/opa/pr/chemed-corp-and-vitas-hospice-services-agree-pay-75-million-resolve-false-claims-act

Bostwick Laboratories

Date of settlement: 2016

Settlement amount: $3.75M

Description: $3.75M FCA and Anti-Kickback statutes settlement for billing Medicare and Medicaid for medically unnecessary cancer detection tests and offering incentives to physicians to obtain Medicare and Medicaid business.

Link: https://www.justice.gov/opa/pr/former-owner-bostwick-laboratories-agrees-pay-375-million-resolve-allegations-unnecessary

Robinson Health System, Inc.

Date of settlement: 2015

Settlement amount: $10M

Description: $10M FCA, Anti-Kickback Statute and Stark Statute settlement involving Robinson’s financial relationships with a number of referring physicians that allegedly violated the Anti-Kickback Statute and the Stark Statute. These relationships included management agreements that Robinson had with two physicians groups. These physicians allegedly failed to provide sufficient bona fide management services to have justified the payments that they received.

Link: https://www.justice.gov/opa/pr/ohio-based-health-system-pays-united-states-10-million-settle-false-claims-act-allegations

TeamHealth Holdings

Date of settlement: 2017

Settlement amount: $60m

Description: FCA settlement for knowingly and systematically encouraged false billings by its hospitalists, who are medical professionals whose primary focus is the medical care of hospitalized patients. Specifically, the government alleged that IPC encouraged its hospitalists to bill for a higher level of service than actually provided. IPC’s scheme to improperly maximize billings allegedly included corporate pressure on hospitalists with lower billing levels to “catch up” to their peers.

Link: https://www.justice.gov/opa/pr/healthcare-service-provider-pay-60-million-settle-medicare-and-medicaid-false-claims-act

Dr. Michael J. Reinstein

Date of settlement: 2015

Settlement amount: $3.79

Description: Dual criminal and civil $3.79 FCA and Anit-Kickback settlement for receiving illegal kickbacks and benefits totaling nearly $600,000 from two pharmaceutical companies in exchange for regularly prescribing an anti-psychotic drug to his patients. Reinstein also agreed to pay the United States and the state of Illinois $3.79 million to settle a parallel civil lawsuit alleging that, by prescribing clozapine in exchange for kickbacks, Reinstein caused the submission of false claims to Medicare and Medicaid for the clozapine he prescribed for thousands of elderly and indigent patients in at least 30 Chicago-area nursing homes and other facilities.

Link: https://www.justice.gov/opa/pr/illinois-physician-pleads-guilty-taking-kickbacks-pharmaceutical-company-and-agrees-pay-379

Kmart Corporation

Date of settlement: 2017

Settlement amount: $32.3

Description: $32.3 FCA settlement for in-store pharmacies within in Kmart stores failing to report discounted prescription drug prices to Medicare Part D, Medicaid, and TRICARE, the health program for uniformed service members and their families, the Justice Department announced today.

Link: https://www.justice.gov/opa/pr/kmart-corporation-pay-us-323-million-resolve-false-claims-act-allegations-overbilling-federal

Phillip B. Klapper, M.D.

Date of settlement: 2/6/2018

Settlement amount: $2.79M

Description: FCA settlement for improper billing of audiological services and hearing aids.

Link: https://www.justice.gov/usao-wdky/pr/kentucky-otolaryngologist-pays-279-million-resolve-false-claims-allegations

King’s Daughters Medical Center

Date of settlement: 2014

Settlement amount: $41m

Description: $41M FCA settlement for medically unnecessary coronary stents and diagnostic catheterizations.

Link: https://www.justice.gov/opa/pr/king-s-daughters-medical-center-pay-nearly-41-million-resolve-allegations-false-billing

Saint Joseph Health System

Date of settlement: 2014

Settlement amount: $16.5M

Description: $16.5M FCA settlement for medically unnecessary cardiac procedures.

Link: https://www.justice.gov/opa/pr/kentucky-hospital-agrees-pay-government-165-million-settle-allegations-unnecessary-cardiac

CR Bard

Date of settlement: 2013

Settlement amount: $48m

Description: CR Bard paid $48m in anti-kickback violations.

Link: https://www.justice.gov/opa/pr/cr-bard-inc-pay-us-4826-million-resolve-false-claims-act-claims

St Joseph’s MC

Date of settlement: 2010

Settlement amount: $22m

Description: Paid $22m in anti-kickback and Stark violations to cardiology group.

Link: https://www.justice.gov/opa/pr/st-joseph-medical-center-maryland-pay-us-22-million-resolve-false-claims-act-allegations

St Joseph’s MC

Date of settlement: 2016

Settlement amount: $3.2m

Description: Paid $3.2m for billing mental-health Medicaid services rendered by unqualified staff.

Link: https://www.justice.gov/usao-ndny/pr/st-joseph-s-hospital-pay-32-million-billing-medicaid-mental-health-services-rendered

Shands Teaching Hospital, Shands Jacksonville Medical Center Inc. and Shands Jacksonville Healthcare Inc

Date of settlement: 2013

Settlement amount: $26m

Description: Paid a total of $26 million to settle allegations that six of its health care facilities submitted false claims to Medicare, Medicaid and other federal health care programs for inpatient procedures that should have been billed as outpatient service. The consultant was the whistleblower.

Link: https://www.justice.gov/opa/pr/shands-healthcare-pay-26-million-resolve-allegations-related-inpatient-stays-six-florida

Halifax Hospital Medical Center and Halifax Staffing Inc

Date of settlement: 2014

Settlement amount: $85m

Description: The government alleged that Halifax knowingly violated the Stark Law by executing contracts with six medical oncologists that provided an incentive bonus that improperly included the value of prescription drugs and tests that the oncologists ordered and Halifax billed to Medicare. The government also alleged that Halifax knowingly violated the Stark Law by paying three neurosurgeons more than the fair market value of their work.

Link: https://www.justice.gov/opa/pr/florida-hospital-system-agrees-pay-government-85-million-settle-allegations-improper

32 hospitals, a number of which were in Florida

Date of settlement: 2015

Settlement amount: $28m

Description: This Kyphoplasty affected 32 hospitals across 15 states – a number of which were in Florida - and resulted in settlement of over $28m. The settlements resolve allegations that the 32 settling hospitals frequently billed Medicare for kyphoplasty procedures on a more costly inpatient basis, rather than an outpatient basis, in order to increase their Medicare billings.

Link: https://www.justice.gov/opa/pr/32-hospitals-pay-us-more-28-million-resolve-false-claims-act-allegations-related-kyphoplasty

Adventist Health System

Date of settlement: 2015

Settlement amount: $115m

Description: $115M settlement settles allegations of improper compensation arrangements with referring physicians.

Link: https://www.justice.gov/opa/pr/adventist-health-system-agrees-pay-115-million-settle-false-claims-act-allegations

Pacific Alliance Medical Center

Date of settlement: 2017

Settlement amount: $42m

Description: Acute care hospital paid $42 million to settle allegations that they violated the False Claims Act by engaging in improper financial relationships with referring physicians. The whistleblower was employed as a manager by the medical centre.

Link: https://www.justice.gov/opa/pr/los-angeles-hospital-agrees-pay-42-million-settle-alleged-false-claims-act-violations-arising

St. Helena Hospital

Date of settlement: 2014

Settlement amount: $2.25m

Description: This acute care hospital within the Adventist Health System agreed to pay the United States $2,250,000 to settle allegations that it submitted false claims to Medicare for certain cardiac procedures and related inpatient admissions. The whistleblower was former employee of St. Helena Hospital.

Link: https://www.justice.gov/usao-ndca/pr/st-helena-hospital-agrees-pay-225-million-settle-false-claims-act-allegations

Tri-city medical center

Date of settlement: 2016

Settlement amount: $3.2m

Description: Settlement resolved allegations that this hospital violated the Stark Law and the False Claims Act by maintaining financial arrangements with community-based physicians and physician groups that violated the Medicare program’s prohibition on financial relationships between hospitals and referring physicians.

Link: https://www.justice.gov/opa/pr/california-hospital-pay-more-32-million-settle-allegations-it-violated-physician-self-0

Active Physical Medicine & Rehab Group Inc.

Date of settlement: 2014

Settlement amount: $2.78

Description: Two companies that operate physical therapy clinics in Washington, D.C., Virginia, and Maryland, along with three individuals associated with the businesses, have agreed to pay the United States $2.78 million to settle allegations that the firms’ billings to Medicare and the TRICARE health care program violated the False Claims Act.

Link: https://www.justice.gov/usao-dc/pr/physical-therapy-clinics-pay-278-million-resolve-false-claims-act-allegations

Valley Heart Consultants

Date of settlement: 2014

Settlement amount: $3.9

Description: Valley Heart Consultants Dr. Carlos Mego and Dr. Subbarao Yarra paid $3.9m to settle allegations of billing Medicare for substandard nuclear stress tests and physical examinations.

Link: https://www.justice.gov/usao-sdtx/pr/us-settles-civil-lawsuit-against-valley-heart-consultantsdoctors

McAllen Hospitals LP

Date of settlement: 2009

Settlement amount: $27.5m

Description: The settlement resolves allegations that the hospitals paid illegal compensation to doctors in order to induce them to refer patients to hospitals within the group.

Link: https://www.justice.gov/opa/pr/texas-hospital-group-pays-us-275-million-settle-false-claims-act-allegations

Planned Parenthood Gulf Coast

Date of settlement: 2013

Settlement amount: $4.3m

Description: The government alleges that between 2003 and 2009, Planned Parenthood Gulf Coast billed and was paid by government programs, Texas Medicaid, Title XX, and the Women’s Health Program, for certain items and services related to birth control counseling, STD testing and contraceptives when such items and services were either not medically necessary, not medically indicated or not actually provided.

Link: https://www.justice.gov/usao-edtx/pr/planned-parenthood-pays-43-million-settle-allegations-unnecessary-medical-care

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No case studies available for this state.