The following is a summary of selected federal Department of Health and Human Services’ Office of Inspector General (OIG) reports of fraud and abuse enforcement activity across the country.[1] The enforcement actions reported are based upon federal and individual states’ activity reported by OIG through its listserv on Enforcement Actions.

The summaries reflect areas of OIG’s and individual states’ current and recent enforcement activity.[2] Knowing where regulators’ attention is focused helps health care providers identify areas of attention for compliance and risk-assessment activities. Although not all the enforcement actions may be relevant to any one provider’s health care business, there may be some summaries that could be used as examples in compliance program education programs (“What to avoid”), or used in developing a risk management plan. (Note: An Acronym Key appears at the end of the Report.)

Of Note in this Issue:

  1. Lincare, Inc. settles allegations that it billed rental fees to federal health care programs for use of certain DME devices that patients no longer needed or used, additionally Lincare allegedly violated the AKS by waiving coinsurance payments to induce certain Medicare and TRICARE beneficiaries to rent the DME involved.  (February 16, 2024.) 
  2. Defendant and co-conspirators sent false banking information for hospitals to OH and CO Medicaid agencies and, when those states’ Medicaid payments were directed to the false hospital bank accounts, the funds were quickly drained with proceeds shared by the Defendant and co-conspirators. (February 2, 2024.)

February 29, 2024 OIG Listserv Release

Doctor Pleads Guilty to Conspiring to Accept Kickbacks in Connection with Fraudulent Telemarketing Scheme Victimizing Medicare and TRICARE Patients in Eastern Washington

WA.  Defendant, a physician, allegedly participated in a telemarketing scheme and conspiracy where a company obtained Medicare and TRICARE beneficiary information by using telemarketers to obtain personal and health information. The company allegedly created fake medical records that falsely and fraudulently reflected doctor visits and treatment that did not exist, the Defendant signed the fraudulent medical orders for DME, and the fraudulent medical orders were then sold by the telemarketing company to other entities that used the fraudulent orders to falsely bill Medicare and TRICARE. The company and the Defendant allegedly billed Medicare and TRICARE for the fictitious doctor visits and exams that did not take place. 

Rockford Skilled Therapy Provider To Pay $1.5 Million To Settle Federal Health Care Fraud Suit

IL.  Defendants were a skilled therapy provider and its current and former owners who allegedly billed Medicare for therapy services when (1) the provider was actually out of the country; (2) the PT or OT services were performed by massage therapists rather than licensed physical therapists or occupational therapists; (3) services were performed by an occupational therapy assistant or physical therapy assistant when they were not properly supervised; (4) therapy services were billed under improper codes to avoid caps on certain services; and (5) occupational and physical therapy when there were no licensed occupational therapists or physical therapists on site. 

The matter was initiated through a Qui Tam action.

Georgia Laboratory Owner Pleads Guilty to Felony Charge and Pays $14.3 Million to Resolve Liability Relating to Kickbacks and Unnecessary Testing

GA.  Defendant was the owner of a clinical lab who allegedly entered into an agreement with an independent contractor sales representative to arrange for, or recommend, medically unnecessary urine drug tests and respiratory pathogen panels (RPP) in return for volume-based commissions in violation of the AKS. The drug screens were performed to satisfy a requirement of a school mentoring services program for at risk teenagers without regard to medical need or patient history.  With the Defendant’s alleged knowledge, his lab paid the mentoring service program a percentage of the reimbursement for samples submitted by the program to the lab. The Defendant and his lab used independent sales representatives who completed test requisition forms for RPP using forged physician signatures to order COVID-19 tests and using sham diagnosis codes that did not reflect the medical conditions of the senior community residents receiving the tests, and the claims were submitted to federal health care programs.

Pharmacy Owner and Operations Manager Convicted of $2.3M Ohio Medicaid Fraud

OH.  Defendants were a pharmacist and a pharmacy tech who allegedly billed for dispensing a particular manufacturer’s omeprazole that was reimbursed at a higher rate than the generic omeprazole actually dispensed, and the pharmacist put protocols in place to dispense omeprazole through a doctor’s prescription even when there was no prescription, in order to maximize profits.

February 28, 2024 OIG Listserv Release

California Man Charged in $10 Million Health Care Fraud, Wire Fraud and Kickback Conspiracy

NJ. Defendant allegedly owned and controlled marketing companies in CA through which he and his co-conspirators identified Medicare beneficiaries to target for at-home cancer genetic tests (CGX) and they used multiple means to obtain personal and medical information from the beneficiaries that included making unsolicited calls to elderly cancer patients. The Defendant and his conspirators allegedly sent CGX test kits to beneficiaries regardless of whether they needed or wanted them and once the kits were completed and returned, the conspiracy submitted claims to Medicare for reimbursement. The Defendant allegedly received kickback payments for each CGX test that resulted in a Medicare payment. To conceal the scheme, the Defendant allegedly wired payments to a New Zealand shell company that then wired the payments to accounts controlled by the Defendant in the U.S., and the shell company allegedly entered into sham contracts that made it appear the Defendant’s marketing companies were providing hourly referral services to the sham company.  

February 23, 2024 OIG Listserv Release

Attorney General Ford Announces Sentencing of Operator of Behavioral Health Company

NV. Defendant, biller for a behavioral health company, allegedly billed for services that were not provided. The Defendant allegedly obtained funds from the payments made by Medicaid for the fraudulent billings.

Attorney General Ford Announces Sentencing of Healthcare Company Owner and Operator

NV. Defendants were excluded from NV Medicaid, but one Defendant allegedly acquired ownership of a behavioral health company and failed to revise the ownership records to reflect his acquisition of the company, and despite being precluded from owning or operating any health care company that received Medicaid funds, the Defendant’s company did receive Medicaid funds.  Additional allegations include that providers at the health care company denied providing services that the Defendants billed to Medicaid.

Florida Man Indicted for Health Care Fraud, Wire Fraud, Illegal Kickbacks in $97 Million Scheme

NJ. Defendant and co-conspirators owned and operated multiple call centers where they obtained doctors’ orders for DME without regard to medical necessity. The DME orders were allegedly provided in exchange for bribes per brace or device.

Doctor to Pay Nearly $700,000 to Resolve False Claims Act Allegations

NJ. Defendant, physician and his practice, allegedly regularly upcoded certain CPT codes to receive a higher reimbursement than was warranted based on the services provided; submitted claims for services the Defendant did not provide to patients by regularly billing for impossible days (a day in which a physician purports to provide such a high volume of services or procedures in one day that there would be no way the physician could perform all the services); and provided services in NJ on days when the Defendant was not physically present in the U.S.

Medical Doctor Charged for $20.7M Health Care Fraud and Illegal Kickback Schemes

NJ. Defendant, a physician, allegedly received cash kickbacks from a lab representative and others in exchange for approving orders for lab tests billed to Medicare. He allegedly participated in COVID-19 testing events at which he authorized COVID-19 tests and expensive and medically unnecessary cancer genetic tests that patients did not request, were not used in patients’ treatment and for which the patients rarely received the results. The Defendant also allegedly billed for lengthy office visits that were never provided to patients. Additionally, the Defendant allegedly solicited and received cash kickbacks and bribes from an owner of a DME supply company in exchange for ordering medically unnecessary, and reimbursement ineligible, braces.

February 20, 2024 OIG Listserv Release

Lexington Lab Agrees to $10.4 Million in Civil Judgments to Resolve False Claims Act Allegations; Owner and Lab Officer Sentenced to Prison

KY. Defendants, a toxicology lab, its owner, and its director of operations/compliance officer, allegedly submitted false claims for urine drug testing services to Medicare and Medicaid. The two non-corporate Defendants knew that Medicaid only paid for medically necessary urine drug tests, but drug tests ordered by courts for use in judicial proceedings are not medically necessary and so not payable to Medicare or Medicaid. Allegedly with the Defendant-owner’s knowledge, the Defendant-compliance officer recruited a company to refer court-ordered drug tests to Defendant-lab which then billed the non-medically necessary tests to Medicare and Medicaid, resulting in fraudulently obtained payments in violation of the FCA. The non-corporate Defendants also allegedly solicited urine drug tests from substance abuse recovery programs that did not provide medical treatment, and the Defendant-compliance officer misled sober home directors, inducing them to send more tests to the Defendant-lab by putting facility staff on the lab’s payroll and compensating them based on the number of urine drug tests sent to the lab, despite knowing those urine drug tests were not for medical purposes when they were billed to Medicare and Medicaid.

The matter was initiated through a Qui Tam action.

Former Delaware Specialty Pharmacy Chief Marketing Officer Agrees to Six-Year Exclusion from Federal Health care Programs for Allegations of Kickback and False Claims Act Violations

PA. Defendant, former Chief Marketing Officer of a specialty pharmacy, allegedly violated the AKS when she directed the pharmacy to pay kickbacks to physicians for referrals and waive Medicare copayments without a determination of beneficiaries’ financial need for the waiver.  The Defendant allegedly directed remuneration to providers in the form of gifts, dinners and free administrative and clinical support services to physicians. 

The matter was initiated through a Qui Tam action.

Owner of Telemedicine Companies Charged with $110 Million Medicare Fraud Scheme

MA. Defendant, owner of telemarketing companies, allegedly entered into business relationships with telemarketing companies that generated leads by targeting Medicare beneficiaries. The telemarketers allegedly paid the Defendant’s companies on a per-order basis to generate orders for DME for the beneficiaries, and the Defendant allegedly worked with medical staffing companies to find doctors and nurses willing to review and sign prepopulated orders, typically without any patient contact, falsely portraying the medical providers as having performed a legitimate examination of the beneficiary. The Defendant allegedly provided the signed orders to telemarketing companies, which sold the orders to DME suppliers that would provide medically unnecessary DME based on false documentation and tainted by kickbacks.

Doctor Convicted of $2.8M Medicare Fraud Scheme

CA. Defendant, a medical director of several hospice companies, allegedly fraudulently certified Medicare patients as having terminal illnesses that the patients did not have so the hospice could bill Medicare for hospice services. The Defendant allegedly was listed as the attending provider for more hospice claims paid by Medicare than any other provider in the nation.

February 16, 2024 OIG Listserv Release

Former Maryland Dentist Sentenced after Pleading Guilty to Stealing More than $8 Million from Medicaid – Patients were Almost Exclusively Children

MD. Defendant, a former dentist, allegedly continued to practice dentistry after losing his license and used the identity of others, forged signatures on Medicaid applications, used aliases to avoid detection, directed his employees to use aliases to avoid accountability, and failed to cooperate with insurance audits. The Defendant allegedly continued to bill for services he did not provide, provided substandard care to patients, used equipment that was not properly sanitized, performed and billed for unnecessary services, bullied and intimidated patients who questioned him and kept very little documentation of services he claimed to have provided. The Defendant allegedly billed under his brothers’ and nephew’s (both were licensed dentists) Medicaid provider numbers and used a provider number of a former colleague to submit fraudulent claims to Medicaid.

AG Platkin Announces Over $6M Seized Under Judgment by Consent After Death of CEO in Medicaid Fraud Scheme

NJ. Defendant, a deceased President and CEO of a chain of mental health clinics, allegedly engaged in a scheme to defraud a Medicaid pharmaceutical company, allegedly violated the FCA by causing the systematic submission of false claims over several years to Medicaid for services not rendered to numerous Medicaid beneficiaries, or for billing at higher-paying individual therapy or family psychotherapy codes when group therapy services were actually performed.

California Pharmaceutical Company to Pay $750,000 to Resolve False Claims Act Liability for Allegedly Paying Kickbacks to Induce Prescriptions of Opioid Products

NJ. Defendant, a pharmaceutical company, allegedly violated the FCA by causing the submission of claims for certain opioids in violation of the AKS. The Defendant allegedly indirectly paid kickbacks to a physician whose girlfriend was employed by the Defendant as a sale representative.  The physician was the top prescriber of the opioids in issue and the sales representative-girlfriend was paid a salary and bonuses to induce the physician to prescribe the Defendant’s opioids. 

U.S. Attorney Announces $25.5 Million Settlement With Durable Medical Equipment Supplier Lincare Inc. For Fraudulent Billing Practices

Lincare Admits That It Received Reimbursements for Claims That Did Not Comply With Billing Rules and Guidance and Continued To Seek Payments in Instances When It Was Aware Patients Were Not Using the Respiratory Equipment

NY. Defendant, a DME supplier, allegedly violated the FCA when it fraudulently continued to bill federal health care programs for the rental of costly non-invasive ventilators (“NIVs”) when patients no longer needed or used the devices. Additionally the Defendant allegedly violated the AKS by waiving coinsurance payments to induce certain Medicare and TRICARE beneficiaries to rent NIVs. The Defendant’s internal policies allegedly were violated when its clinical staff frequently failed to visit NIV patients every 60 days to confirm patients were using the NIVs as directed by physicians; some of Defendant’s locations lacked sufficient staff to adequately monitor patient progress and confirm that patients were using the devices as directed; and clinical staff sometimes did not perform home visits for NIV patients for several months. The Defendant allegedly failed to remotely monitor certain patients’ NIV usage where newer NIV models allowed such monitoring.

The matter was initiated through a Qui Tam action.

February 15, 2024 OIG Listserv Release

Houston man convicted in $6M bribery scheme

TX. Defendant was an employee at a dental clinic who allegedly paid marketers cash, sometimes putting the illegal kickbacks on top of a vending machine down the hall from the clinic. The Defendant was allegedly warned by the clinic manager that paying marketers was illegal. In addition to the alleged payments of kickbacks, the Defendant allegedly participated in the dental clinic’s receipt of payment for dental services that were not provided.

February 14, 2024 OIG Listserv Release

Holy Health Care Services, LLC Program Administrator Sentenced to Five Years in Federal Prison for a Health Care Fraud Scheme

MD. Defendant, a program administrator at Holy Health which provided mental health services, allegedly, with his co-conspirators, paid Medicaid beneficiaries to come into the office and then used their personally identifiable information (PII) to bill Medicaid for services that were not rendered or were not rendered as billed. The Defendant allegedly made up fake Holy Health employees so he could bill Medicaid for services provided by those fake employees.

February 12, 2024 OIG Listserv Release

Florida Felon Admits Role in Multi-Million Dollar Health Care Kickback Scheme After Pleading Guilty to COVID-19 Fraud and Unlawfully Possessing Firearms

FL. See the summary for NJ on February 9, 2024 under the headline:  Florida Man Admits Role in Multimillion-Dollar Health Care Kickback Scheme

Testing Laboratory Co-owner Admits $3.8 Million in Fraudulent Billing

MO. Defendant is a former health care company owner and his co-conspirator allegedly opened an in-house testing lab which they held out as a clinical testing lab that was in the same building and used the same testing machine as another business owned by the co-conspirator. They allegedly sought accreditation for both labs under the Clinical Laboratory Improvement Amendments (“CLIA”), but the pair did not disclose that both labs would employ the same part-time employee who would perform tests using the same machine. It is also alleged that misrepresentations were made in order to obtain the CLIA certification and they also concealed co-ownership from Medicare, Medicaid and private health insurers. They and other health care providers at their non-lab health care businesses ordered urine toxicology tests and referred them to the subject labs which in turn sent the samples to outside “reference” labs as they allegedly knew they did not have the necessary testing equipment and then they billed health insurers for the testing, despite prohibitions on “pass through billing.” The Defendant and co-conspirator allegedly used their multiple labs to submit specimens obtained from the same person on the same day of service (“split-billing”), using the CLIA certified lab’s CLIA number.

February 9, 2024 OIG Listserv Release

TennCare Fraud Investigation Leads to Indictment of Newport Man

TN. Defendant allegedly was a caregiver for an adult relative and he submitted claims for services that were never provided.

Attorney General Raoul Obtains Conviction of Physician Who Defrauded State Out of More Than $1 Million of Medicaid Funding

IL. Defendant is allegedly a licensed physician that owned a center providing tutoring services to children, as well as clinical therapy and psychiatric services. The Defendant and his niece allegedly submitted numerous claims to Medicaid for psychotherapy and medical services that were not provided.

AG Campbell Reaches $1.6M Settlement with North Dartmouth Ambulance Companies to Resolve False Billing Allegations

MA. Defendants include the owner and her two transportation companies; they allegedly submitted false claims to Medicaid when they “upcoded” claims to misrepresent their rendered services in order to file more expensive claims. This allegedly included billing for emergency services when only nonemergency services were provided, for providing medically unnecessary services, instructing employees to falsify service documentation to support “upcoded” claims and to routinely fail to comply with Medicaid’s and federal requirements regarding medical necessity forms for non-emergency transportation services.

Florida Man Admits Role in Multimillion-Dollar Health Care Kickback Scheme

NJ. Defendant and his conspirators allegedly owned and operated marketing call centers and telemedicine companies through which they obtained doctors’ orders for DME without regard to medical necessity. The Defendant and the conspirators provided doctors’ orders in exchange for bribes from DME companies that provided braces to Medicare beneficiaries.

Outside the scope of this summary are the allegations that the Defendant submitted fraudulent statements for Economic Injury Disaster Loans and Paycheck Protection Program loans and allegations regarding unlawful possession of firearms and ammunition.

February 8, 2024 OIG Listserv Release

Penn State Health Agrees To Pay More Than Eleven Million Dollars Following Its Voluntary Disclosure Of Improper Billings Related To Medicare Annual Wellness Visit Services

PA. Defendant, multihospital health system, allegedly submitted claims to Medicare for Annual Wellness Visit services that violated Medicare rules and regulations in that they were not supported by the medical record. This was voluntarily disclosed by the Defendant and the Defendant is reported to have taken prompt corrective action.

Pharmacy Owner and Administrator Admit Roles in Multimillion-Dollar Health Care Fraud and Kickback Scheme

NJ. Defendants, a co-owner and administrator of a number of pharmacies, allegedly operated a specialty pharmacy that processed expensive medications and obtained retail network agreements with several PBMs which allowed them to receive payments for prescription medications, including specialty medications. In order to obtain a higher volume of prescriptions, the Defendants allegedly paid bribes (cash, checks, wire transfers, expensive meals, other things of value, including paying an employee to work inside a doctor’s office) to doctors and doctors’ employees to induce them to steer prescriptions to Defendants’ businesses. The Defendants allegedly engaged in pervasive and fraudulent practice of billing health benefit providers and PBMs for medications that were never provided to patients, which was accomplished in part through systematically billing for refills that were never dispensed. It was alleged that when PBMs conducted routine audits of one of Defendant’s pharmacies, one of the Defendants instructed his employees to falsify records submitted to the PBMs. 

February 6, 2024 OIG Listserv Release

False Claims Act Complaint Filed Against Former President and Co-Owner of Mobile Cardiac PET Scan Provider

TX. Defendant, a former president, CFO and co-owner of a provider of mobile cardiac positron emission tomography (PET) scans, allegedly took a central role in his corporation’s payment of exorbitant, above-fair market value fees to doctors who referred patients for cardiac PET scans in violation of the Stark Law. It is alleged that, in an effort to increase profits, the Defendant caused his company to enter into improper compensation arrangements with cardiologists who referred patients and were paid as if they were fully occupied supervising the PET scans, even though the cardiologists were actually providing care to other patients in their offices or were not even on site, and such fees purportedly compensated the cardiologists for additional services beyond the supervision that was actually provided. 

The matter was initiated through a Qui Tam action.

February 5, 2024 OIG Listserv Release

Pomona Hospital Agrees to Pay More Than $2 Million after Self-Reporting Overbilling of Medi-Cal for Prescription Medications

CA. Defendant, a hospital, allegedly improperly charged higher UCR costs, rather than lower “actual acquisition costs,” under the federal 340B Drug Pricing Program that requires drug manufacturers to provide outpatient medication to eligible health care organizations at significantly reduced prices. The Defendant allegedly overbilled the United States and CA when it billed its UCR costs following a federal court’s temporary stay on the implementation of the CA law requiring 340B providers to bill Medi-Cal at actual acquisition costs. It is alleged that when the court lifted the temporary ban, the Defendant failed to implement actual acquisition cost pricing.

The Defendant voluntarily disclosed the matter and cooperated with federal and state investigations.

Man Sentenced for Over $600M Health Care Fraud, Wire Fraud, and Identity Theft Scheme

NY. Defendant, an operator of medical billing companies, allegedly used those companies as a third-party medical biller to bill insurance companies and request reconsideration or appeals of denied claims. He allegedly received a percentage of the amount paid by insurance companies. It was alleged the Defendant billed for procedures that were either more serious or entirely different from those his doctor-clients performed, that he made calls in which he impersonated patients and patients’ relatives to induce insurance companies to reconsider denied claims or pay more on approved claims, and he received a percentage of the fraudulent proceeds. The Defendant directed his doctor-clients to schedule elective surgeries through the ER so that insurance companies would reimburse at substantially higher rates. On denial of those claims, the Defendant allegedly again impersonated patients to demand that the insurance companies pay the outstanding balances.

February 2, 2024 OIG Listserv Release

Memphis Woman Arrested Following TennCare Fraud Investigation

TN. Defendant, a caregiver, allegedly submitted claims for overlapping caregiver services between two patients in violation of TN Medicaid rules.

Baltimore County Serial Fraudster Sentenced to Five Years in Federal Prison and Ordered to Pay $4.2 Million in Restitution

MD. Defendant and his co-conspirators allegedly obtained money that the OH and CO Medicaid programs and the state of OH sought to pay hospitals in OH and CO. The Defendant and co-conspirators allegedly sent false information to an OH government office and CO Medicaid regarding back accounts on file for the hospitals and when the states transferred funds into the alleged bank accounts controlled by a co-conspirator, the funds were quickly transferred and the Defendant shared in the proceeds of the fraud scheme.

Outside the scope of this summary are allegations related to bank fraud and identity theft on financial crimes.

February 1, 2024 OIG Listserv Release

Former Employee of Eye For Change Youth and Family Services Sentenced to Prison for Fraudulent Medicaid Billing Practices

OH. Defendant allegedly billed Medicaid for services not actually performed or for services that were not actually performed for the amount of time the billing codes reflected. The Defendant allegedly falsified progress notes and used the identities of clients without authorization to bill Medicaid.

Glastonbury Psychologist Admits Defrauding Medicaid of More Than $1.6 Million

CT. Defendant, a psychologist enrolled in Medicaid as a behavioral health clinician, allegedly submitted claims for dates of service when no services were provided to Medicaid clients identified on claims, including periods when the Defendant was traveling, on vacation, recovering from surgery, or otherwise not working. Additional allegations include Defendant submitted claims when appointments were canceled, when the client was hospitalized, when Defendant stopped treating the claimed client and when the claimed client was never his client. Defendant also allegedly treated multiple clients in the same family at the same time and he billed the group visit as multiple individual claims which is not permitted by Medicaid.

CORPORATE INTEGRITY and INTEGRITY AGREEMENTS – NEW CASES

December 18, 2023 – effective date: Reported February 14, 2024
CorePath Laboratories, PA – Integrity Agreement (IA)
*  3-year Corporate Integrity Agreement
*  IRO to review for AKS and Stark Law violations related to Arrangements which are defined as arrangements between CorePath and any actual or potential referral source or any actual or potential recipient of health care business or referrals from CorePath. The IRO must also have expertise in fair-market valuation issues.

January 3, 2024 – effective date: Reported February 2, 2024
Edgewater Recovery Center – Corporate Integrity Agreement (CIA)
*  5-year Corporate Integrity Agreement
*  Covered Conduct: The Clinical lab allegedly performed urine drug tests for a drug rehabilitation facility despite knowing the tests were not typically used for patients’ medical diagnosis or treatment. The lab billed for urine drug screens performed on the rehab facility’s specimens without a proper medical order requesting the test.

HHS-OIG Advisory Opinions Posted During February 2024

2024-01 – posted February 26, 2024
Favorable Opinion regarding the use of a “preferred hospital” network as part of Medigap policies where the insurance company contracts with a PHO to provide discounts on otherwise applicable Medicare inpatient deductibles for its policyholders, and the insurance company would provide a premium credit of $100 off the next renewal premium to policyholders who use the network hospital for an inpatient stay.

Key:
AG = Attorney General
AKS = Anti-Kickback Statute
CIA = Corporate Integrity Agreement
CMP = Civil Monetary Penalties
CMS = Centers for Medicare and Medicaid Services
CPT  = Current Procedural Terminology Codes        
DOJ  =  United States Department of Justice
DME = Durable Medical Equipment
E&M = Evaluation & Management services
ER = Emergency Department or Emergency Room
EMTALA = Emergency Medical Treatment and Labor Act
FEHBP = Federal Employees Health Benefits Program
FMV = Fair Market Value
DOJ = United States Department of Justice
FCA = False Claims Act
FWA = Fraud, Waste & Abuse
HHS = Department of Health and Human Services
HRSA = HHS’s Health Resources and Services Administration
IA = Integrity Agreement
LTC = Long Term Care (usually facilities)
MCO = Managed Care Organization (typically Medicaid)
MFCU = Medicaid Fraud Control Unit
MSO  = Management Services Organization
NH = Nursing Home
NPI = National Provider Identifier
OIG = Office of Inspector General in HHS
OT = Occupational Therapy
PBM = Pharmacy Benefit Managers
PHI = Personal Health Information
PHO = Preferred Hospital Organization
PII = Personally Identifying Information
PT = Physical Therapy
SNF = Skilled Nursing Facility
UCR = Usual Customary and Reasonable


[1] Not included in the summaries are prosecutions related solely to drug diversion and inappropriate prescriptions, patient fiscal or physical abuse, or non-health care related matters such as money laundering as a specific allegation that may be in conjunction with an alleged fraud or misuse of COVID-19 relief funds. The summaries also do not include enforcement announcements of arrests with no report of an indictment or civil complaint or announcements related to sentencing following a conviction or guilty plea.

[2] The summaries should be considered to reflect allegations and not necessarily be considered to be statements of fact.