Mississippi Businessman Sentenced to 18 Years in Prison For $288 Million Tricare Fraud Scheme

George F. Indest III with 30+ years of experience, is Board Certified in Health LawBy George F. Indest III, J.D., M.P.A., LL.M., Board Certified by The Florida Bar in Health Law

On January 15, 2021, a Mississippi man was sentenced to 18 years in prison by a federal judge for his role in a $287.6 million scheme to defraud the Tricare health benefits program. According to the U.S. Department of Justice (DOJ), he committed fraud by paying doctors and drug distributors kickbacks.

What is Tricare?

Tricare is the health care benefit program serving active-duty military personnel, military retirees, and their dependents worldwide. The program provides comprehensive coverage to all beneficiaries, including health plans, special programs, prescriptions, and dental plans. Learn more about Tricare here.

Conspiracy to Commit Health Care Fraud and Money Laundering.

In July 2020, he pled guilty to orchestrating a $287.6 million scheme to defraud Tricare by paying doctors and drug distributors kickbacks. The kickbacks were in exchange for unnecessary compounded medication prescriptions sent to his pharmacies. He admitted to tampering with drug formulas and bribing doctors to authorize prescriptions to rake in reimbursements from the federal benefits program. Read the complaint in full.

More Details of the Fraud Scheme.

According to the government, from 2012 to 2016, he used marketing companies, drug distributors, and compounding pharmacies that he owned to contract with other pharmacies to provide prescriptions for the medications.

He admitted to creating prescription pads with the drug formulas for doctors to push the expensive drugs onto patients easily. In exchange for participating in the fraud, doctors got a cut of the pharmacy benefits managers and programs’ reimbursements.

Additionally, he and his co-conspirators conducted illegal wire transfers of millions of dollars in illegally obtained cash to various companies and bank accounts. The government said he personally obtained more than $40 million from the scheme.

As part of his plea agreement, he is ordered to forfeit more than $50 million worth of property, luxury cars, and an airplane. He was also ordered Friday by U.S. District Judge Keith Starrett of the Southern District of Mississippi to pay $287,659,569 in restitution. Click here to view the plea agreement.

To read about a similar Tricare fraud case in Florida, click here to read one of my prior blogs.

Contact Health Law Attorneys Experienced in Representing Pharmacies and Pharmacists.

The Health Law Firm represents pharmacists, pharmacies, doctors, and medical groups in DEA, DOH, FDA, OIG, and DOJ investigations, qui tam and whistleblower cases, regulatory matters, licensing issues, litigation, administrative hearings, inspections, and audits. The Firm also represents both plaintiffs (whistleblowers or relators) and defendants in False Claims Act (whistleblower or qui tam) cases. The firm’s attorneys include those who are board-certified by The Florida Bar in Health Law as well as licensed health professionals who are also attorneys.

To contact The Health Law Firm please call (407) 331-6620 or (888) 331-6620 and visit our website at www.TheHealthLawFirm.com.

Sources:

Clough, Craig. “Miss. Businessman Gets 18 Years For $288M Tricare Fraud.” Law360. (January 15, 2021). Web.

Stawicki, Kevin. “Miss. Businessman Pleads Guilty To $288M Tricare Fraud.” Law360. (July 10, 2020). Web.

About the Author: George F. Indest III, J.D., M.P.A., LL.M., Board Certified by The Florida Bar in Health Law is an attorney with The Health Law Firm, which has a national practice. Its main office is in the Orlando, Florida, area. www.TheHealthLawFirm.com The Health Law Firm, 1101 Douglas Ave. Suite 1000, Altamonte Springs, Florida 32714, Phone: (407) 331-6620 or toll-free: (888) 331-6620.

“The Health Law Firm” is a registered fictitious business name of and a registered service mark of The Health Law Firm, P.A., a Florida professional service corporation, since 1999.
Copyright © 2021 The Health Law Firm. All rights reserved.

 

Judge Refuses to Dismiss $21 Million Suit against Florida Pharmacy Alleging Illegal Kickback Scheme

George Indest HeadshotBy George F. Indest III, J.D., M.P.A., LL.M., Board Certified by The Florida Bar in Health Law

On February 13, 2019, a federal judge turned down a Florida pharmacy’s motion to dismiss a $21 million False Claims Act (FCA) suit, but allowed its sister company out of the suit. The judge said Z Stat Medical LLC, which operates as Oldsmar Pharmacy and its owner, must face the government’s claims that it engaged in illegal kickback schemes to defraud Tricare. Oldsmar’s sister company, Stat Direct LLC, was dismissed from the lawsuit completely. There was no evidence it was also involved in the alleged misconduct, according to court documents.

The First Alleged Scheme.

The case was originally brought as a result of a whistleblower complaint that alleged two schemes to defraud Tricare. The first scheme was allegedly a deal between Oldsmar and Centurion Compounding Pharmacy. Centurion was alleged to have hired sales reps as independent contractors. The sales reps marketed costly compounded medications, usually creams for pain and scars, to Tricare beneficiaries. Patients recruited by the sales reps were told to send their prescriptions to Centurion, which then directed them to Oldsmar to fill. The sales representatives would then get part of the reimbursement profit, according to the complaint.

In total, Tricare was stated to have paid about $18 million for these bogus claims, and Oldsmar was alleged to have paid about $6.1 million in kickbacks in a little over a year, the suit says.

The Second Alleged Scheme.

The second alleged scheme involved companies that included Health Savings Solutions and Vici Marketing. Oldsmar allegedly worked with Vici Marketing and published online advertisements offering free consultations. Referrals were funneled through Health Savings Solutions for compounded pain creams. These prescriptions were written and filled, without a patient ever seeing a doctor in person, according to court documents.

According to the government, from September 2014 to February 2015, Oldsmar Pharmacy filed 700 prescription claims with Tricare based on referrals from Health Savings Solutions. In return, Oldsmar Pharmacy paid a 41 percent kickback to the marketers. This resulted in Tricare paying out about $3.4 million. Oldsmar made $5.5 million in payments to Health Savings Solutions, including three payments of about $1 million each, according to the complaint.

Click here to read the complaint in full.

Liable for False Claims.

Judge Hernandez Covington said the government pled the allegations sufficiently to keep Oldsmar and its owner in the case. The government has also satisfactorily alleged that Oldsmar’s owner has enough of an understanding of the Anti-Kickback Statutes (AKS) to have known better, according to the Judge.

While Oldsmar Pharmacy did return $19 million to Tricare, the FCA calls for treble damages Three times the amount), so the company can’t avoid litigation, the judge said, adding that she’ll deduct the $19 million from any final amount determined top be owed.

Click here to read the judge’s order in full.

To read about a case Judge Hernandez Covington made a similar ruling on dealing with a Florida Compounding Pharmacy’s FCA Suit, click here to read one of my prior blogs. (https://www.thehealthlawfirm.com/blog/posts/federal-judge-refuses-to-dismiss-florida-compounding-pharmacys-fca-suit.html)

Contact Health Law Attorneys Experienced in Representing Pharmacies and Pharmacists.

The Health Law Firm represents pharmacists and pharmacies in DEA, DOH and FDA investigations, qui tam and whistleblower cases, regulatory matters, licensing issues, litigation, administrative hearings, inspections and audits. The firm’s attorneys include those who are board certified by The Florida Bar in Health Law as well as licensed health professionals who are also attorneys.

To contact The Health Law Firm please call (407) 331-6620 or (850) 439-1001 and visit our website at www.TheHealthLawFirm.com.

Sources:

Kass, Dani. “Pharmacy Must Face $21M Prescription Kickback Suit.” Law360. (February 13, 2019). Web.

“13 IN TAMPA CHARGED AS PART OF NATIONAL HEALTHCARE FRAUD TAKEDOWN.” Tampa Bay Reporter. (June 29, 2018). Web.

Hale, Nathan. “Feds Want FCA Suit Over $21M Kickback Scheme To Proceed.” Law360. (January 28, 2019). Web.

About the Author: George F. Indest III, J.D., M.P.A., LL.M., is Board Certified by The Florida Bar in Health Law. He is the President and Managing Partner of The Health Law Firm, which has a national practice. Its main office is in the Orlando, Florida, area. www.TheHealthLawFirm.com The Health Law Firm, 1101 Douglas Ave., Altamonte Springs, FL 32714, Phone: (407) 331-6620.

KeyWords: False Claims Act defense attorney, FCA legal counsel, TRICARE false claims legal defense attorney, TRICARE physician representation, legal representation violating False Claims Act, pharmaceutical fraud lawyer, compounding pharmacy attorney, fraudulent practices of pharmaceutical companies, whistleblower lawyer, whistblower defense attorney, representation for FCA violations, financial interest in physician referrals, TRICARE fraud attorney, The Health Law Firm, representation for healthcare fraud investigations, conflict of interest in physician referrals, representation for compounding pharmacies, compounding pharmacy defense lawyer, prescription reimbursement representation, Anti-Kickback Statute (AKS) attorney, Anti-Kickback Statute (AKS) violations lawyer, representation for kickback allegations, representation for allegations of fraud, legal defense of military physicians, legal defense of TRICARE providers, FDA investigation attorney, representation for FDA investigations, DEA defense attorney, representation for DEA investigations against healthcare professionals, representation for DOH investigations, DOH investigation attorney, attorney reviews of The Health Law Firm, Veterans Administration (VA) physician defense attorney, The Health Law Firm attorney reviews, legal representation for pharmacies, legal representation for pharmacists, health law defense attorney, legal representation for health care professionals

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By |2019-02-21T18:20:05-05:00February 21st, 2019|Categories: Pharmacy Law Blog|Tags: , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , |0 Comments

Florida Pharmacy Hit With FCA Suit for Illegal Kickback Scheme Targeting Tricare

George IndestBy George F. Indest III, J.D., M.P.A., LL.M., Board Certified by The Florida Bar in Health Law

On October 19, 2018, the federal government filed suit against a Florida pharmacy for allegations of illegal kickback schemes involving industry marketers. The U.S. Attorney’s Office for the Middle District of Florida alleges that Oldsmar Pharmacy was involved in illegal schemes that resulted in the federal Tricare program paying more than $21 million in reimbursements for prescriptions and False Claims Act (FCA) violations.

Suit Filed on Behalf of The Defense Health Agency (DHA).

The federal government filed the suit on behalf of the U.S. Department of Defense, including its Defense Health Agency (DHA). The DHA administers the Tricare program, which provides health insurance for active duty military personnel, military retirees and their dependents.

The government is seeking treble damages, civil penalties and restitution, based on its claims that the pharmacy submitted claims to Tricare for reimbursement for prescriptions of costly compound medications. The government claims that they knew were fraudulent under the FCA because of the kickbacks paid to marketers.

On October 18, 2018, the U.S. Department of Justice (DOJ) released a press release announcing the involvement of three military members in the scheme as sales representatives for Centurion Compounding, Inc. All three were indicted for paying kickbacks to Tricare beneficiaries to obtain prescriptions for compounded medications. You can learn more about this in the section below.21

Click here to read the DOJ’s press release.

Former Whistleblower Suit.

The lawsuit against Oldsmar Pharmacy and company President, Larry Smith, stems from a whistleblower suit filed in 2015 by Jennifer Silva and Jessica Robertson, former employees, according to the complaint.

The schemes allegedly occurred between September 2014 and February 2015 by Smith and Oldsmar and different pharmacy services administration organizations.

Tricare Reimbursements and Kickback Schemes.

According to the complaint, Centurion Compounding Inc., hired sales representatives as independent contractors who marketed costly compound medications to Tricare beneficiaries. Patients recruited by the sales reps were directed to send their prescriptions to Centurion, which then directed them to Oldsmar pharmacy.

From November 2014 to February 2015, Tricare paid about $18 million for approximately 4,000 claims for compound prescriptions as part of the kickback scheme, according to the federal government. Oldsmar paid Centurion more than $6.1 million in kickbacks, some of which was distributed to the individual sales representatives involved.

Additionally, prosecutors claim that pharmacy President, Larry Smith, entered into a second kickback scheme with several marketing companies. These companies published online advertisements offering free consultations for pain creams via telemedicine, without ever seeing a physician in person. In return, Oldsmar Pharmacy paid a 41 percent kickback to the marketers, the complaint alleges.

Click here to read the complaint in full.

The suit brings forward false or fraudulent claims; recovery of payments made by mistake by Tricare; and unjust enrichment. To learn more, click here to read one of my prior blogs on a similar case.

Contact Health Law Attorneys Experienced in Representing Pharmacies and Pharmacists.

The Health Law Firm represents pharmacists and pharmacies in DEA, DOH and FDA investigations, qui tam and whistleblower cases, regulatory matters, licensing issues, litigation, administrative hearings, inspections and audits. The Firm also represents both plaintiffs (whistle blowers or relators) and defendants in False Claims Act (whistle blower or qui tam) cases. The firm’s attorneys include those who are board certified by The Florida Bar in Health Law as well as licensed health professionals who are also attorneys.

To contact The Health Law Firm please call (407) 331-6620 or (850) 439-1001 and visit our website at www.TheHealthLawFirm.com.

Sources:

Hale. Nathan. “Fla. Pharmacy Hit With False Claims Suit Over Kickbacks.” Law360. (October 19, 2018). Web.

Stringini, Mary. “St. Pete doctor pleads guilty to receiving kickbacks, BMW in $5.3 million pharmacy conspiracy.” ABC Action News. (March 8, 2018). Web.

About the Author: George F. Indest III, J.D., M.P.A., LL.M., Board Certified by The Florida Bar in Health Law is an attorney with The Health Law Firm, which has a national practice. Its main office is in the Orlando, Florida, area. www.TheHealthLawFirm.com The Health Law Firm, 1101 Douglas Avenue, Altamonte Springs, Florida 32714, Phone: (407) 331-6620.

KeyWords: Pharmacy legal representation, False Claims Act defense attorney, FCA legal counsel, Anti-Kickback Statute (AKS) defense attorney, legal representation for allegations of violating Anti-Kickback Statute, TRICARE false claims legal defense attorney, TRICARE physician representation, legal representation violating False Claims Act, pharmaceutical fraud lawyer, compounding pharmacy attorney, fraudulent practices of pharmaceutical companies, whistle blower lawyer, FCA violations representation, pharmacy representation, pharmacy defense attorney, pharmacist representation, pharmacist defense lawyer, TRICARE fraud attorney, The Health Law Firm, fraud investigations representation, health care fraud defense lawyer, compounding pharmacy lawyer, prescription reimbursement leagl representation, legal defense of military physicians, legal defense of TRICARE providers, attorney reviews of The Health Law Firm, Veterans Administration (VA) physician defense attorney, The Health Law Firm attorney reviews

“The Health Law Firm” is a registered fictitious business name of and a registered service mark of The Health Law Firm, P.A., a Florida professional service corporation, since 1999.
Copyright © 2019 The Health Law Firm. All rights reserved.

Florida Pharmacist Gets More Than Six Years in Prison For Role in Compounding Fraud Scheme

Attorney George F. Indest IIIBy George F. Indest III, J.D., M.P.A., LL.M., Board Certified by The Florida Bar in Health Law

On November 29, 2018, a Florida pharmacist was sentenced to six and a half years in prison and ordered to pay $3.4 million, for her role in a scheme to defraud the government. Marjorie Robinson pled guilty one count of conspiracy to commit health care fraud for submitting fraudulent claims to Tricare, Medicare and private insurance programs for compounded creams that were not necessary.

The Fraud Scheme.

According to the U.S. Department of Justice (DOJ), Robinson was one of three owners of ASC Pharmacy Inc., a now defunct compounding pharmacy in Miami. Under her direction, the pharmacy made compounded creams that were made to maximize reimbursement from government and private insurance programs, not for patients needs, according to the plea deal. Click here to read the press release from the DOJ.

The other owners were charged separately and have also pled guilty.

This isn’t the first time a Florida pharmacy has defrauded government programs like Tricare, click here to read one of my prior blogs on a similar case.

Health Care Fraud Should Not Be Taken Lightly.

We have been consulted by many individuals, both before and after criminal charges were brought for fraud or related offenses. In many cases, those subject to Medicare and Medicaid fraud audits and investigations refuse to acknowledge the seriousness of the matter. Some may even decide not to spend the money required for a highly experienced health attorney to defend them.

Click here to read one of my previous blog posts regarding Medicare and Medicaid audits.

The government is serious about combating health care fraud. It created a Medicare Fraud Strike Force in March of 2007, in an effort to further prevent and eliminate fraud and abuse of government health care programs. False claims are a growing problem in the program, costing the government billions of dollars each year. Accordingly, punishments for defrauding the system can be quite severe.

If you are accused of Medicare or Medicaid fraud, realize that you are in a fight for your life. Your liberty, property/possessions and profession are all at stake. Often it is possible to settle allegations of fraud by agreeing to pay civil monetary penalties and fines. If given such an opportunity, the provider should consider whether it is worth the risk of facing decades in prison. Be prepared to give up whatever you need to in order to avoid a conviction and preserve your liberty.

Don’t Wait Until It’s Too Late; Consult with a Health Law Attorney Experienced in Medicare and Medicaid Issues Now.

The attorneys of The Health Law Firm represent pharmacists and healthcare providers in Medicare audits, ZPIC audits and RAC audits throughout Florida and across the U.S. They also defend pharmacists, physicians, pharmacies and medical groups in actions by Tricare, Medicare, Medicaid and private insurers to recoup overpayments, obtain civil fines and penalties and take other actions against them. They represent pharmacies and pharmacists in DEA actions and administrative (Order to Show Cause ) hearings, Medicare Fraud Control Unit (MFCU) investigations, and administrative and civil litigation, physicians, medical groups, nursing homes, home health agencies, pharmacies, hospitals and other healthcare providers and institutions in Medicare and Medicaid investigations, audits, recovery actions and termination from the Medicare or Medicaid Program.

For more information please visit our website at www.TheHealthLawFirm.com or call (407) 331-6620 or (850) 439-1001.

Sources:

Bolado, Carolina. “Fla. Pharmacist Gets 6½ Years For Bogus Claims For Creams.” Law360. (November 29, 2018). Web.

“South Florida pharmacist sentenced to more than six years in prison for role in $3.4 million compounding pharmacy scheme.” MD Linx. (November 30, 2018). Web.

About the Author: George F. Indest III, J.D., M.P.A., LL.M., is Board Certified by The Florida Bar in Health Law. He is the President and Managing Partner of The Health Law Firm, which has a national practice. Its main office is in the Orlando, Florida area. www.TheHealthLawFirm.com The Health Law Firm, 1101 Douglas Ave., Altamonte Springs, FL 32714, Phone: (407) 331-6620.

KeyWords: Legal representation for pharmacists, pharmacy lawyer, legal representation for pharmacies, pharmacists lawyer, legal representation for healthcare fraud, health care fraud representation, healthcare fraud defense lawyer, legal representation for submitting false claims to the government, False Claims Act defense attorney, FCA legal counsel, FCA defense lawyer, Anti-Kickback Statute (AKS) defense attorney, FCA representation, legal representation for allegations of violating Anti-Kickback Statute, AKS representation, TRICARE false claims legal defense attorney, TRICARE physician representation, legal representation violating False Claims Act, pharmaceutical fraud lawyer, compounding pharmacy attorney, fraudulent practices of pharmaceutical companies, Medicare audit defense attorney, ZPIC audit defense lawyer, RAC audit defense legal counsel, pharmacy Tricare audit defense attorney, Medicare pharmacy defense lawyer, Medicaid audit of pharmacy defense counsel, pharmacy defense attorney for overpayment demand, pharmacy civil fine defense attorney, pharmacy DEA defense attorney, pharmacy Order to Show Cause (OTSC) defense lawyer, Medicare Fraud Control Unit (MFCU) investigation defense legal counsel, pharmacy administrative and civil litigation attorney, health care fraud defense legal representation, TRICARE fraud attorney, health law defense attorney, health care fraud defense attorney, The Health Law Firm, representation for health care fraud investigations, compounding pharmacy lawyer, prescription reimbursement representation, pharmacy defense attorney, pharmacist defense lawter, representation for pharmacies, representation for pharmacists, legal representation for health care facilities, representation for health care professionals, legal defense of TRICARE providers, U.S. Department of Justice (DOJ) investigation representation, DOJ defense attorney, representation for DOJ matters, attorney reviews of The Health Law Firm, The Health Law Firm attorney reviews

“The Health Law Firm” is a registered fictitious business name of and a registered service mark of The Health Law Firm, P.A., a Florida professional service corporation, since 1999.
Copyright © 2018 The Health Law Firm. All rights reserved.

By |2018-12-26T19:49:51-05:00December 26th, 2018|Categories: Pharmacy Law Blog|Tags: , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , |0 Comments

Florida Pharmacy Owner to Serve 15 Years in Prison for $100 Million Billing Fraud Scheme

George F. Indest III HeadshotBy George F. Indest III, J.D., M.P.A., LL.M., Board Certified by The Florida Bar in Health Law

On April 26, 2018, the owner of several Florida pharmacies was sentenced to 15 years in prison and ordered to give up $54.5 million in restitution. Nicholas A. Borgesano Jr., owner of A to Z Pharmacies, pled guilty to his role in a $100 million scheme involving bogus insurance reimbursements for prescription drugs.

He pled guilty in November to charges of conspiracy to commit health care fraud and conspiracy to engage in monetary transactions in property derived from specified unlawful activity, according to the order. Click here to read more.

Health Care Billing Fraud Schemes. 

According to prosecutors, Borgesano was at the center of an alleged scheme in which the pharmacy owner used his six stores to peddle prescription compound medications. He would then submit fraudulent reimbursement claims to Medicare, Tricare and private insurance companies.

Borgesano and his co-conspirators are accused of manipulating billing codes in the reimbursement claims and submit claims for pharmaceutical ingredients they didn’t even have. Additionally, he used one of his pharmacies in Florida as the hub of operations and paid his co-conspirators through shell companies, checks and the purchase of assets, prosecutors said.

From the pharmacy owner and his group of conspirators, the U.S. Department of Justice (DOJ) has seized $7.6 million worth of property, including several luxury vehicles and a 50-foot racing boat, the DOJ said. To read more about the co-conspirators, click here to read the press release issued by the DOJ.

To read the judgement in full click here.

The expensive prescription medications and creams involved in this case have been targeted by prosecutors in a handful of other Florida suits alleging Medicare and Tricare fraud by pharmacy owners and others. Click here to read one of my prior blogs involving a similar case.


Contact Health Law Attorneys Experienced in Representing Pharmacies and Pharmacists.

The Health Law Firm represents pharmacists and pharmacies in DEADOH and FDA investigations, qui tam and whistleblower cases, regulatory matters, licensing issues, litigationadministrative hearings, inspections and audits. The firm’s attorneys include those who are board certified by The Florida Bar in Health Law as well as licensed health professionals who are also attorneys.

To contact The Health Law Firm please call (407) 331-6620 or (850) 439-1001 and visit our website at www.TheHealthLawFirm.com.

Sources:

Greene, Kat. “Pharmacy Owner Gets 15 Years For Role In $100M Scheme.” Law360. (April 27, 2018). Web.

Manning, Margie. “New Port Richey pharmacy owner sentenced in $100 million fraud scheme.” Tampa Bay Business Journal. (April 26, 2018). Web.

About the Author: George F. Indest III, J.D., M.P.A., LL.M., is Board Certified by The Florida Bar in Health Law. He is the President and Managing Partner of The Health Law Firm, which has a national practice. Its main office is in the Orlando, Florida area. www.TheHealthLawFirm.com The Health Law Firm, 1101 Douglas Ave., Altamonte Springs, FL 32714, Phone: (407) 331-6620.

KeyWords: False Claims Act defense attorneyFCA legal counselFCA defense lawyer, Anti-Kickback Statute (AKSdefense attorneyFCA representation, legal representation for allegations of violating Anti-Kickback StatuteAKS representation, TRICARE false claims legal defense attorney, TRICARE physician representation, legal representation violating False Claims Act, pharmaceutical fraud lawyer, compounding pharmacy attorney, fraudulent practices of pharmaceutical companies, FCA violations attorneyhealth care fraud representation, TRICARE fraud attorneyhealth law defense attorneyhealth care fraud defense attorney, The Health Law Firm, representation for health care fraud investigations, compounding pharmacy lawyer, prescription reimbursement representation, pharmacy defense attorneypharmacist defense lawter, representation for pharmacies, representation for pharmacistslegal representation for health care facilities, representation for health care professionals, legal defense of TRICARE providers, U.S. Department of Justice (DOJ) investigation representation, DOJ defense attorney, representation for DOJ matters, attorney reviews of The Health Law Firm, The Health Law Firm attorney reviews

“The Health Law Firm” is a registered fictitious business name of and a registered service mark of The Health Law Firm, P.A., a Florida professional service corporation, since 1999.
Copyright © 2018 The Health Law Firm. All rights reserved.

A Prescription for Love Fraud

10 Indest-2008-7By George F. Indest III, J.D., M.P.A., LL.M., Board Certified by The Florida Bar in Health Law

In May of 2015, Tricare began screening all compound medication prescriptions to ensure approval of each ingredient with the Food and Drug Administration (FDA). This decision came after a finding of a significant increase in compound drug prescriptions reimbursed by Tricare over the last year.

In April 2015, just four months into the fiscal year, it was already determined that total costs for compound drug prescriptions filled for Tricare recipients were likely to come close to $1 billion. If the trend continues, the Defense Health Agency expects it may need to reallocate funds at the end of this year to cover the prescription drug benefit, which is currently set at $8.25 billion.

For more on this new screening process and its effect on compound medication prescriptions, click here.

With prescription drug costs at an all-time high, the government is cracking down on health care fraud. This includes the implementation of data mining for fraud detection and prevention.

It was during one of these routine mining expeditions of reimbursement data that the United States Attorney’s Office identified MediMix, a compounding pharmacy in Jacksonville, Florida, as the top-biller of compounding pain prescriptions. More importantly, upon further investigation, it was found that Ankit Desai, M.D. was the top referring physician for MediMix.

The significance in the correlation between the two is that, according to reports, Dr. Desai happens to be married to one of the top executives (Senior Vice President) of Medimix.

To read the press release on this story, click here.

When Marriage and Money Clash.

Health care providers are generally prohibited from referring patients to another medical-related business in which they hold a financial interest of some kind, if there are payments made with federal funds.

The prohibition on certain physician referrals is established under Section 1395nn, 42 United States Code (otherwise known as the Stark Law). The Stark Law states in pertinent part:

“…if a physician (or an immediate family member of such physician) has a financial relationship with an entity specified in paragraph (2), then–

(A) the physician may not make a referral to the entity for the furnishing of designated health services for which payment otherwise may be made under this subchapter, and

(B) the entity may not present or cause to be presented a claim under this subchapter or bill to any individual, third party payor, or other entity for designated health services furnished pursuant to a referral prohibited under subparagraph (A).” Section 1395nn (a)(1)(A)(B), 42 United States Code.

Paragraph (2) of Section 1395nn (a), 42 United States Code, defines “a financial relationship of a physician (or an immediate family member of such physician) with an entity specified in this paragraph” as:

(A) except as provided in subsections (c) and (d) of this section, an ownership or investment interest in the entity, or

(B) except as provided in subsection (e) of this section, a compensation arrangement (as defined in subsection (h)(1) of this section) between the physician (or an immediate family member of such physician) and the entity.

An ownership or investment interest described in subparagraph (A) may be through equity, debt, or other means and includes an interest in an entity that holds an ownership or investment interest in any entity providing the designated health service.” Section 1395nn (a)(2)(A)(B), 42 United States Code.

The Stark Law was specifically enacted to place limitations on physician referrals so as to avoid:

(1) conflicts of interests;

(2) self-referrals;

(3) overutilization of services;

(4) increased health care costs;

(5) a limit on competition by other medical providers;

(6) to prevent ineffective and unsafe treatment; and, ultimately-

(7) fraudulent practices.

Click here for more information on the most common Federal fraud and abuse laws in health care.

 

Tricare Regulations Similar to Stark and Anti-Kickback Regulations.

In support of its position, the United States Attorney’s Office relied on Section 199.9, 32 Code of Federal Regulations, which provides “administrative remedies for fraud, abuse, and conflict of interest.” More specifically, Section 199.9(c)(12) defines fraud as:

“Arrangements by providers with employees, independent contractors, suppliers, or others which appear to be designed primarily to overcharge the [Tricare program] through various means (such as commissions, fee-splitting, and kickbacks) used to divert or conceal improper or unnecessary costs or profits.”

Furthermore, due to the application of this more open-ended regulation, whistleblowers that may come forward as a result of the allegations made in this False Claims Act (FCA) case, may be granted more latitude in making arguments. Alternatively, under the Stark Law, the same arguments might have been moot as a result of its explicit exceptions not found in Tricare regulations.

We’ll Call it the Honeymoon Fund.

MediMix reached a settlement agreement with the government which has avoided a determination of liability. However, the Jacksonville-based compounding pharmacy did not get off without a significant penalty. The settlement will cost MediMix an impressive $3,775,458.

Click here to read more about the government cracking down on what they determine to be “a significant threat to the [Department of Defense] DoD healthcare system.”

Avoiding the”Dog House.”

The FCA has been highly effective in exposing fraudulent practices of pharmaceutical companies. Whistleblower cases brought under the FCA have assisted the government in recovering more than $19 billion in stolen funds due to varying pricing, billing and marketing schemes.

Here are the most common pharmaceutical practices that may land you in the “dog house” for a FCA violation:

(1) Off-label marketing of drugs;

(2) Illegal kickbacks;

(3) Inflating the price of pharmaceuticals;

(4) Best price fraud; and

(5) Pharmaceutical benefits manager fraud.

Click here to read more information about these common pharmaceutical schemes and how to identify and consequently avoid them.

If you find yourself in a tricky situation with possible allegations of a FCA violation, it’s best to contact an experienced health attorney immediately to properly evaluate your case and inform you of your rights.

For more about your right to consult with a lawyer prior to speaking with an investigator, please read one of our previous blogs here.

Comments?
Are you currently engaged in a questionable financial relationship? Do you agree with the law on prohibiting certain referrals in which there is a financial interest? Why or why not?

Contact Health Law Attorneys Experienced in Representing Pharmacies and Pharmacists.

The Health Law Firm represents pharmacists and pharmacies in DEA, DOH and FDA investigations, qui tam and whistleblower cases, regulatory matters, licensing issues, litigation, administrative hearings, inspections and audits. The firm’s attorneys include those who are board certified by The Florida Bar in Health Law as well as licensed health professionals who are also attorneys.

To contact The Health Law Firm please call (407) 331-6620 or (850) 439-1001 and visit our website at www.TheHealthLawFirm.com.


Sources:

Department of Justice, The United States Attorney’s Office, Middle District of Florida. Press release. “United States Settles False Claims Act Allegations Against Jacksonville-Based Compounding Pharmacy.” 1 June 2015. Web. 11 Sept. 2015.

Kime, Patricia. “Tricare to Start Screening Compound Medications Friday.” Military Times. A TEGNA Co., 1 May 2015. Web. 10 Sept. 2015.

“Pharmaceutical Fraud” Web blog post. False Claims Act Resource Center. Pietragallo Gordon Alfano Bosick & Raspanti, LLP, 2015. Web. 11 Sept. 2015.

Rumph, Alan, and Donna Lee Yesner. “When Referrals And Marriage Don’T Mix: MD, Pharmacy Settle Case.” Report on Medicare Compliance. Washington: Atlantic Information Services, Inc., 8 June 2015. Web. 11 Sept. 2015.

About the Author: George F. Indest III, J.D., M.P.A., LL.M., is Board Certified by The Florida Bar in Health Law. He is the President and Managing Partner of The Health Law Firm, which has a national practice. Its main office is in the Orlando, Florida area. www.TheHealthLawFirm.com The Health Law Firm, 1101 Douglas Ave., Altamonte Springs, FL 32714, Phone: (407) 331-6620.

Keywords: False Claims Act defense attorney, FCA, pharmaceutical fraud, compounding pharmacy attorney, fraudulent practices of pharmaceutical companies, whistleblowers lawyer, FCA violations, fraud detection, data mining, financial interest in physician referrals, Stark Law, Department of Defense, DoD, Tricare fraud attorney, health attorney, defense attorney, The Health Law Firm, health law firm, fraud investigations, conflict of interest in physician referrals, compound medication prescriptions, compounding pharmacy lawyer, prescription reimbursement, qui tam attorney, financial relationship with physician

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“The Health Law Firm” is a registered fictitious business name of George F. Indest III, P.A. – The Health Law Firm, a Florida professional service corporation, since 1999. Copyright © 1996-2015 The Health Law Firm. All rights reserved.

X-Ray Company Owner Receives 10 Years in Prison For $8M Medicare and Medicaid Fraud Which Lead to the Death of Two Patients

George IndestBy George F. Indest III, J.D., M.P.A., LL.M., Board Certified by The Florida Bar in Health Law
On June 15, 2016, A medical diagnostics company owner found guilty of Medicare and Medicaid fraud for billing $8 million for X-rays whose botched analysis by amateurs led to the death of two patients was sentenced in Maryland federal court to 10 years in prison, the U.S. Department of Justice said. The diagnostics company, Alpha Diagnostics, LLC (Alpha), operated in Maryland, Delaware, Pennsylvania, Virginia and Washington, D.C.

Alpha’s president and chief executive officer (CEO) Rafael Chikvashvili, was convicted by a jury in February 2016 of two counts of health care fraud resulting in death, nine counts of health care fraud, eight counts of wire fraud, one count of conspiracy, 11 counts of false statements relating to health care matters and two counts of aggravated identity theft.

I previously wrote a blog covering this case. Click here to read it.

A Mathematician, NOT a Physician.

Chikvashvili, who is a mathematician and not a physician, provided X-rays, ultrasounds and other portable diagnostics in Alpha’s different locations. “The jury found that two patients died because their X-rays were not reviewed by a qualified radiologist. Health care fraud has consequences,” U.S. Attorney Rod Rosenstein said in statements in February and again on Wednesday.

The Consequences of His Actions.

According to prosecutors, Chikvashvili improperly ordered nonphysician employees to interpret X-rays, ultrasounds and cardiology exams, then submitted false claims to the government for reimbursement. Additionally, he ordered workers to make up physicians’ examination reports and improperly copied physicians’ signatures, sometimes even forging them himself, prosecutors said.

Not only did he defraud the government out of thousands of dollars, two patients died as a result of his actions. “The evidence showed that Rafael Chikvashvili failed to provide medical services to patients who needed them, billed for services he did not provide. The jury found that two patients died because their X-rays were not reviewed by a qualified radiologist. Health care fraud has consequences, in money wasted and lives lost.” U.S. Attorney Rod J. Rosenstein said in a statement.

The case is U.S. v. Chikvashvili, case number 1:14-cr-00423, in the U.S. District Court for the District of Maryland.

At The Health Law Firm, we have experience with cases such as this. Click here to read a press release for a previous client we represented in which our attorneys succeeded in having the physician dismissed from a six million dollar suit.

Contact Health Law Attorneys Experienced in Handling Medicare Audits, Investigations and other Legal Proceedings.

The Health Law Firm’s attorneys routinely represent physicians, dentists, orthodontists, medical groups, clinics, pharmacies, assisted living facilities (AFLs), home health care agencies, nursing homes, group homes and other healthcare providers in Medicaid and Medicare investigations, audits and recovery actions.

To contact The Health Law Firm please call (407) 331-6620 or (850) 439-1001 and visit our website at www.TheHealthLawFirm.com.

Source:

Salvatore, Cara. “X-Ray Co. Owner Gets 10 Years For $8M Fraud, 2 Deaths.” Law360. (June 15, 2016). Web.

About the Author: George F. Indest III, J.D., M.P.A., LL.M., is Board Certified by The Florida Bar in Health Law. He is the President and Managing Partner of The Health Law Firm, which has a national practice. Its main office is in the Orlando, Florida area. www.TheHealthLawfirm.com The Health Law Firm, 1101 Douglas Ave., Altamonte Springs, FL 32714, Phone; (407) 331-6620.
KeyWords: Health care fraud defense lawyer, false claims act defense attorney, submitting false claims to the government, fraudulent reimbursements, health care fraud resulting in death, U.S. Department of Justice (DOJ) prosecutions for healthcare fraud, civil monetary penalties lawyer, Medicare audit defense attorney, Medicare appeal legal, Medicare claims appeals lawyer, Medicare defense attorney, federal administrative complaint defense lawyer, Food & Drug Administration (FDA) audit defense attorney, Medicare appeals lawyer, health care legal counsel, Medicaid audit defense attorney, Medicare investigation defense, health law attorney, Florida health law attorney, The Health Law Firm

“The Health Law Firm” is a registered fictitious business name of George F. Indest III, P.A. – The Health Law Firm, a Florida professional service corporation, since 1999. Copyright © 2016 The Health Law Firm. All rights reserved.

Home Health Care Company Admits to FCA Violations, Agrees to Pay Millions

By George F. Indest III, J.D., M.P.A., LL.M., Board Certified by The Florida Bar in Health Law
On July 7, 2016, a Kentucky-based home health care chain, MD2U Holding Co. (MD2U), agreed to pay up to $21.5 million and admit False Claims Act (FCA) violations. According to the U.S. Department of Justice (DOJ), the deal is in connection with “extreme” billing practices that saw Medicare billed for false and unnecessary treatments.

The Complaint.

According to a complaint filed, MD2U frequently utilized billing codes reserved for the highest level of treatment when delivering primary care services in residential settings. The frequency with which the codes were used by MD2U made the company an “extreme outlier” among Medicare providers, the complaint said. The DOJ also described several other aspects of MD2U’s scheme. For example, it said that MD2U overbilled Medicare by “embellishing and, at times, fabricating the homebound and home-limited status of its patients.” “MD2U’s corporate culture was a one-code-fits-all mentality,” regardless of medical necessity, the DOJ wrote.

Click here to read the complaint in full.

The Deal.

MD2U and its various subsidiaries struck a deal with the DOJ that denies any intentional wrongdoing but also accepts responsibility for the submission of false claims from the time frame of mid-2007 to late 2014. The fraudulent overbilling was “due in part to the actions of a former employee,” according to a consent judgment. Click here to read the consent judgement in full.

MD2U, which also operates in Florida, agreed to dish out $21.5 million through a payment structure. Specifically, MD2U agreed to an up front payment sum of $300,000 and guaranteed payments over the next five years totaling $3 million. Additionally, MD2U also promised to hand over 25 percent to 50 percent of its net income annually through the year 2021. Click here to read the DOJ’s press release.

To learn more about the repercussions of fraudulent overbilling, click here to read one of my prior blogs.

Contact Health Law Attorneys Experienced in Handling Medicare Audits, Investigations and other Legal Proceedings.

The Health Law Firm’s attorneys routinely represent physicians, dentists, orthodontists, medical groups, clinics, pharmacies, assisted living facilities (AFLs), home health care agencies, nursing homes, group homes and other healthcare providers in Medicaid and Medicare investigations, audits and recovery actions.

To contact The Health Law Firm please call (407) 331-6620 or (850) 439-1001 and visit our website at www.TheHealthLawFirm.com.

Sources:

Overley, Jeff. “Home Care Co. Inks $21.5M FCA Deal Over ‘Extreme’ Billing.” Law360. (July 7, 2016). Web.

Greer, Carolyn. “MD2U, owners admit violating federal law, agree to pay millions.” Louisville Business Journal. (July 8, 2016). Web.

About the Author: George F. Indest III, J.D., M.P.A., LL.M., is Board Certified by The Florida Bar in Health Law. He is the President and Managing Partner of The Health Law Firm, which has a national practice. Its main office is in the Orlando, Florida area. www.TheHealthLawfirm.com The Health Law Firm, 1101 Douglas Ave., Altamonte Springs, FL 32714, Phone; (407) 331-6620.

KeyWords: Home health care, Health care fraud defense lawyer, False Claims Act (FCA) violations, False Claims Act defense attorney, submitting false claims to the government, fraudulent reimbursements, fraudulent overbilling, unnecessary medical tests and procedures, questionable billing practices, U.S. Department of Justice (DOJ) prosecutions for healthcare fraud, civil monetary penalties lawyer, Medicare audit defense attorney, Medicare appeal legal, Medicare claims appeals lawyer, Medicare defense attorney, federal administrative complaint defense lawyer, home health care legal counsel, Medicare investigation defense, health law attorney, Florida health law attorney, The Health Law Firm

“The Health Law Firm” is a registered fictitious business name of George F. Indest III, P.A. – The Health Law Firm, a Florida professional service corporation, since 1999. Copyright © 2016 The Health Law Firm. All rights reserved.

Appeals Court Rules Against Nursing Home: Bankruptcy Cannot Affect Prevent Cancellation of Medicare or Medicaid Contacts

By George F. Indest III, J.D., M.P.A., LL.M., Board Certified by The Florida Bar in Health Law
On July 11, 2016, a federal appeals court stated that a bankruptcy judge did not have the authority to block government health officials from cutting off Medicare and Medicaid payments to a Florida nursing home that was alleged to have violated patient-care regulations. A three-judge panel of the 11th U.S. Circuit Court of Appeals sided with the U.S. Department of Health and Human Services (HHS) and the Florida Agency for Health Care Administration (AHCA) in the dispute with nursing home operator Bayou Shores SNF LLC (Bayou Shores).

The Violations.

In 2014, state inspectors cited a St. Petersburg nursing home operated by Bayou Shores. Contending that the violations posed a threat to patients’ health and safety, federal officials notified Bayou Shores that they were terminating an agreement that included Medicare payments, according to the court’s decision.

Bayou Shores subsequently filed for Chapter 11 bankruptcy protection and asked the bankruptcy court to prevent the state and federal agencies from ending the Medicare payment agreements. The bankruptcy judge sided with Bayou Shores and blocked the termination of the contracts. This led the government agencies to appeal to the local U.S. District Court.

Bankruptcy Court Did Not Have Jurisdiction.

The U.S. District Court judge ruled that the bankruptcy court did not have jurisdiction over the payment agreements, prompting Bayou Shores to appeal the case to the U.S. Eleventh Circuit Court of Appeals. After review, the three-judge panel issued a 66-page ruling on Monday July 18, 2016. The decision gave a detailed analysis of federal legislation involving federally funded healthcare programs and bankruptcy law. It and upheld the ruling by the U.S. District judge concluding that the bankruptcy court did not have jurisdiction to make a decision affecting the agreement.

Click here to read the 66 page ruling.

“HHS, not the bankruptcy court, has been charged by Congress with administering the Medicare Act and regulating Medicare providers,” the ruling written by Judge Raymond Clevenger III said. “And though charged with broad jurisdiction to deal with issues related to a debtor’s bankruptcy estate, bankruptcy courts generally lack the institutional competence or technical expertise of HHS to oversee the health and welfare of nursing home patients or to interpret and administer a ‘massive, complex health and safety program such as Medicare.’”

Don’t Wait Until It’s Too Late; Consult with a Health Law Attorney Experienced in Medicare and Medicaid Issues Now.

The attorneys of The Health Law Firm represent healthcare providers in Medicare audits, ZPIC audits and RAC audits, surveys and inspections of nursing homes, and termination of Medicare and Medicad provider agreements, throughout Florida and across the U.S. We also represent physicians, medical groups, nursing homes, home health agencies, assisted living facilities, pharmacies, hospitals, occupation therapists (OTs), physical therapists (PTs), speech therapists (STs), rehabilitation therapists (RTs) and other healthcare providers and institutions in Medicare and Medicaid investigations, audits, recovery actions and termination from the Medicare or Medicaid program.

For more information please visit our website at www.TheHealthLawFirm.com or call (407) 331-6620 or (850) 439-1001.

 

Sources:

Morning Edition. “Appeals court rules against nursing home in Medicare fight.” Tampa Bay Business Journal. (July 12, 2016). Web.

Brahm, Phil. “Court confirms: Nursing home can’t use bankruptcy to preserve Medicare, Medicaid agreements.” McKnight’s. (July 12, 2016). Web.

About the Author: George F. Indest III, J.D., M.P.A., LL.M., is Board Certified by The Florida Bar in Health Law. He is the President and Managing Partner of The Health Law Firm, which has a national practice. Its main office is in the Orlando, Florida area. www.TheHealthLawfirm.com The Health Law Firm, 1101 Douglas Ave., Altamonte Springs, FL 32714, Phone; (407) 331-6620.

KeyWords: Health care fraud defense lawyer, false claims act defense attorney, submitting false claims to the government, fraudulent reimbursements, unnecessary medical tests and procedures, questionable patient admission practices, nursing home survey attorney, U.S. Department of Justice (DOJ) prosecutions for healthcare fraud, U.S. Department of Health and Human Services (HHS), Medicare and Medicaid termination, OIG exclusion, civil monetary penalties lawyer, Medicare and Medicaid audit defense attorney, Medicare and Medicaid claims appeals lawyer, federal administrative complaint defense lawyer, health care legal counsel, Medicare and Medicaid investigation defense, termination of Medicare and Medicaid provider agreements, health law attorney, Florida health law attorney, The Health Law Firm

“The Health Law Firm” is a registered fictitious business name of George F. Indest III, P.A. – The Health Law Firm, a Florida professional service corporation, since 1999. Copyright © 2016 The Health Law Firm. All rights reserved.

Florida Compounding Pharmacy Pays $3.7 Million in Tricare False Claims Settlement

2 Indest-2009-1By George F. Indest III, J.D., M.P.A., LL.M., Board Certified by The Florida Bar in Health Law

In May of 2015, Tricare began screening all compound medication prescriptions to ensure approval of each ingredient with the Food and Drug Administration (FDA). This decision came after a finding of a significant increase in compound drug prescriptions reimbursed by Tricare over the last year.

In April 2015, just four months into the fiscal year, it was already determined that total costs for compound drug prescriptions filled for Tricare recipients were likely to come close to $1 billion. If the trend continues, the Defense Health Agency expects it may need to reallocate funds at the end of this year to cover the prescription drug benefit, which is currently set at $8.25 billion.

For more on this new screening process and its effect on compound medication prescriptions, click here.

With prescription drug costs at an all-time high, the government is cracking down on health care fraud. This includes the implementation of data mining for fraud detection and prevention.

It was during one of these routine mining expeditions of reimbursement data that the United States Attorney’s Office identified MediMix, a compounding pharmacy in Jacksonville, Florida, as the top-biller of compounding pain prescriptions. More importantly, upon further investigation, it was found that Ankit Desai, M.D. was the top referring physician for MediMix.

The significance in the correlation between the two is that, according to reports, Dr. Desai happens to be married to one of the top executives (Senior Vice President) of Medimix.

To read the press release on this story, click here.

Anti-Fraud Laws Prohibit Certain Physician Referrals.

Health care providers are generally prohibited from referring patients to another medical-related business in which they hold a financial interest of some kind, if there are payments made with federal funds.

The prohibition on certain physician referrals is established under Section 1395nn, 42 United States Code (otherwise known as the Stark Law). The Stark Law was specifically enacted to place limitations on physician referrals so as to avoid:

(1) conflicts of interests;

(2) self-referrals;

(3) overutilization of services;

(4) increased health care costs;

(5) a limit on competition by other medical providers;

(6) to prevent ineffective and unsafe treatment; and, ultimately-

(7) fraudulent practices.

Click here for more information on the most common Federal fraud and abuse laws in health care.

The Stakes are High for Non-Compliance.

MediMix reached a settlement agreement with the government which has avoided a determination of liability. However, the Jacksonville-based compounding pharmacy did not get off without a significant penalty. The settlement will cost MediMix an impressive $3,775,458.

Click here to read more about the government cracking down on what they determine to be “a significant threat to the [Department of Defense] DoD healthcare system.”

The FCA has been highly effective in exposing fraudulent practices of pharmaceutical companies. Whistleblower cases brought under the FCA have assisted the government in recovering more than $19 billion in stolen funds due to varying pricing, billing and marketing schemes.

To read more about the importance of complying with Stark and other anti-fraud laws, read one of our previous blogs here.

Avoiding False Claims Violations.

Here are the most common pharmaceutical practices that can result in allegations of FCA violations:

(1) Off-label marketing of drugs;

(2) Illegal kickbacks;

(3) Inflating the price of pharmaceuticals;

(4) Best price fraud; and

(5) Pharmaceutical benefits manager fraud.

If you find yourself in a tricky situation with possible allegations of a FCA violation, it’s best to contact an experienced health attorney immediately to properly evaluate your case and inform you of your rights.

For more about your right to consult with a lawyer prior to speaking with an investigator, please read one of our previous blogs here.

Comments?
Are you currently engaged in a questionable financial relationship? Do you agree with the law on prohibiting certain referrals in which there is a financial interest? Why or why not? Please leave any thoughtful comments below.

Contact Health Law Attorneys Experienced in Representing Pharmacies and Pharmacists.

The Health Law Firm represents pharmacists and pharmacies in DEA, DOH and FDA investigations, qui tam and whistleblower cases, regulatory matters, licensing issues, litigation, administrative hearings, inspections and audits. The firm’s attorneys include those who are board certified by The Florida Bar in Health Law as well as licensed health professionals who are also attorneys.

To contact The Health Law Firm please call (407) 331-6620 or (850) 439-1001 and visit our website at www.TheHealthLawFirm.com.

Sources:

Department of Justice, The United States Attorney’s Office, Middle District of Florida. Press release. “United States Settles False Claims Act Allegations Against Jacksonville-Based Compounding Pharmacy.” 1 June 2015. Web. 11 Sept. 2015.

Kime, Patricia. “Tricare to Start Screening Compound Medications Friday.” Military Times. A TEGNA Co., 1 May 2015. Web. 10 Sept. 2015.

“Pharmaceutical Fraud” Web blog post. False Claims Act Resource Center. Pietragallo Gordon Alfano Bosick & Raspanti, LLP, 2015. Web. 11 Sept. 2015.

Rumph, Alan, and Donna Lee Yesner. “When Referrals And Marriage Don’T Mix: MD, Pharmacy Settle Case.” Report on Medicare Compliance. Washington: Atlantic Information Services, Inc., 8 June 2015. Web. 11 Sept. 2015.

About the Author: George F. Indest III, J.D., M.P.A., LL.M., is Board Certified by The Florida Bar in Health Law. He is the President and Managing Partner of The Health Law Firm, which has a national practice. Its main office is in the Orlando, Florida area. www.TheHealthLawFirm.com The Health Law Firm, 1101 Douglas Ave., Altamonte Springs, FL 32714, Phone: (407) 331-6620.

Keywords: False Claims Act defense attorney, FCA, pharmaceutical fraud, compounding pharmacy attorney, fraudulent practices of pharmaceutical companies, whistleblowers lawyer, FCA violations, fraud detection, data mining, financial interest in physician referrals, Stark Law, Department of Defense, DoD, Tricare fraud attorney, health attorney, defense attorney, The Health Law Firm, health law firm, fraud investigations, conflict of interest in physician referrals, compound medication prescriptions, compounding pharmacy lawyer, prescription reimbursement, qui tam attorney, financial relationship with physician

“The Health Law Firm” is a registered fictitious business name of George F. Indest III, P.A. – The Health Law Firm, a Florida professional service corporation, since 1999.
Copyright © 1996-2015 The Health Law Firm. All rights reserved.

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