Monthly Archives: May 2026
“Incident-To” Billing Violations: When Supervision Gaps Become Federal Fraud Allegations
“Incident-to” billing under Medicare can be a legitimate and efficient way for physician practices to deliver care through nurse practitioners, physician assistants, and other qualified staff while billing under a supervising physician’s provider number. But the rules are technical, the supervision requirements are strict, and small misunderstandings can carry outsized consequences. In today’s enforcement… Read More »
Laboratory Referral Schemes: Defending Physicians In Toxicology And Genetic Testing Investigations
Federal enforcement efforts have increasingly focused on laboratory referral arrangements, particularly in the areas of toxicology screening and genetic testing. What often begins as a seemingly legitimate clinical workflow, such as ordering tests to diagnose, monitor, or guide treatment, can be reframed by prosecutors as part of an unlawful referral scheme. Physicians who rely… Read More »
Phantom Billing Allegations: Defending Against Claims Of Services Never Rendered
Among the most serious accusations a healthcare provider can face is “phantom billing,” which is the claim that services were billed to Medicare or other payors but never actually provided. Unlike disputes over medical necessity or coding interpretation, phantom billing allegations strike at the core of a provider’s integrity. Prosecutors often present these cases… Read More »
Medical Necessity Disputes: When Clinical Judgment Is Reframed As Criminal Conduct
Few issues in healthcare fraud enforcement are as complex or as controversial as disputes over medical necessity. At its core, medical necessity is supposed to reflect a physician’s clinical judgment: an informed, patient-specific decision based on training, experience, and the facts presented at the time of care. Yet in federal investigations, those same decisions… Read More »
Split Billing And Shared Visits: Criminal Exposure In Hospital And Group Practice Settings
In modern healthcare delivery, physicians frequently collaborate with nurse practitioners and physician assistants to provide timely, efficient care, especially in hospital and group practice settings. “Split” or “shared” visit billing (often called split/shared E/M services) is designed to reflect that collaborative model. But the rules governing how services are divided, documented, and billed are… Read More »
