United States of America, et al. v. Heal 360 Urgent Care PLLC, Heal 360 Primary Care PLLC, and Dr. Mohammed Amer Mohiuddin

Dallas, Texas, qui tam lawyers represented the Plaintiff on a False Claims Act , 31 U.S.C. 3729, theory claiming that the Defendants knowingly submitted or caused the submission of false claims to the Health Resources & Services Administration COVID-19 Claims Reimbursement to Health Care Providers and Facilities for Testing, Treatment, and Vaccine Administration for the Uninsured Program (the “Uninsured Program”) for evaluation and management services that were not performed.

Heal 360 Urgent Care PLLC, Heal 360 Primary Care PLLC (together “Heal 360”) and Dr. Mohammed Amer Mohiuddin knew that appropriate CPT Codes for services provided at the COVID test sites were specimen collection codes, but nevertheless submitted claims under CPT Codes for Higher Level E/M Services that were reimbursed at substantially higher rates than reimbursements for specimen collection.

In order to create the appearance that Higher Level E/M Services were being performed, Heal 360 and Mohiuddin created fictitious, template-generated medical records to correspond to the dates of service for testing that made it appear as if E/M services occurred, for example by including sections for “past medical history” and “examination.” The charts were generated by remote scribes located overseas who input information collected at the COVID test sites into the records. Although Mohiuddin did not visit or treat patients at the COVID tests sites, he was listed on the majority of the claims as the rendering physician. Heal 360 and Mohiuddin submitted hundreds of thousands of claims by the Heal 360 entities to the Uninsured Program for Higher Level E/M Services, and as a result received payment to which they were not entitled.

The United States contended that during the PHE, under Mohiuddin’s oversight and direction, the Heal 360 entities operated and provided services at dozens of COVID-19 testing sites in Texas, the vast majority of which were walk up or drive through testing sites (the “COVID test sites”). Patients could register online or at the site to receive a COVID-19 test, and at the COVID test sites, patients remained in their vehicles while Heal 360 staff checked them in and performed specimen collection services through nasal swabs for COVID-19 tests. No other medical treatment was rendered.

Settled for $20 million.

The civil claims settled by the agreement are allegations only, and there has been no determination of civil liability.