Columbia, South Carolina — Doctors Care, a prominent urgent care network in South Carolina, and its management entity, UCI Medical Affiliates of South Carolina, Inc. (UCI), have agreed to a significant settlement of $22.5 million. This resolution addresses civil allegations of healthcare fraud, specifically violations of the False Claims Act. The announcement was made by Acting United States Attorney for the District of South Carolina, M. Rhett DeHart.
The case originated from a whistleblower complaint highlighting alleged fraudulent practices by Doctors Care, UCI, and UCI Medical Affiliates, Inc., a related holding company. The core of the allegation was that these entities falsely certified urgent care visits as being conducted by healthcare providers properly credentialed to bill government healthcare programs like Medicaid, Medicare, and TRICARE. Contrary to these certifications, the services were purportedly rendered by providers lacking the necessary billing credentials.
Federal healthcare programs mandate that physicians and mid-level providers must apply for and secure explicit approval to bill for services. This approval process establishes a provider’s “billing credentials.” These credentials require periodic renewal and must be re-obtained upon changes in employment.
The allegations state that from 2013 through 2018, UCI struggled to obtain and maintain the necessary billing credentials for a substantial number of Doctors Care providers. UCI was reportedly aware that federal insurance programs would reject claims submitted under the billing number of a provider without proper credentials. Instead of rectifying the credentialing issues or temporarily holding claims for resolution, UCI allegedly engaged in a scheme of submitting false claims. This involved “linking” uncredentialed rendering providers to credentialed billing providers to ensure claim payments.
Each instance of “linked” billing is alleged to constitute a knowingly submitted false claim. Evidence supporting these allegations includes internal emails documenting UCI’s “linking” scheme and so-called “cheat sheets” used by employees. These “cheat sheets” were designed to track credentialed billing providers whose names could be fraudulently substituted on bills for uncredentialed providers.
It is important to note that the “billing credentials” in question are separate from a provider’s medical degree or license. The investigation found no evidence suggesting that Doctors Care providers lacked medical licenses or that patient care was compromised as a direct result of the billing conduct.
Acting U.S. Attorney DeHart emphasized the importance of regulatory compliance for healthcare companies operating within the federal system. “When healthcare companies do business with the federal government, they must follow the rules like everyone else,” stated DeHart. “All companies with this distinction – regardless of size – should honor their commitment to provide competent care to the full letter of the law. Our office will continue to protect tax dollars and ensure the rule of law is followed.”
Derrick L. Jackson, Special Agent in Charge of the Office of Inspector General for the U.S. Department of Health and Human Services (HHS-OIG), echoed this sentiment. “Taxpayers and Medicare patients rightly expect medical providers to be properly credentialed before billing for their services,” Jackson said. “Working with our law enforcement partners, we will continue protecting Federal healthcare programs.”
Special Agent in Charge Christopher Dillard of the DCIS Mid-Atlantic Field Office highlighted the collaborative effort in uncovering this fraud. “The results of this investigation exemplify the commitment of the United States Department of Defense Criminal Investigative Service (DCIS) and its law enforcement partners to root out fraud and corruption involving unscrupulous companies that undermine the integrity of the Department of Defense,” said Dillard. “This case should serve as a stark warning to those who attempt to exploit Department of Defense resources for personal gain.”
The $22.5 million settlement concludes an investigation spanning over three years, spearheaded by the United States Attorney’s Office in collaboration with HHS-OIG and DCIS. Significantly, upon receiving the initial investigative subpoena in early 2018, UCI and Doctors Care management reportedly took swift action to investigate and cease the practices that led to the settlement.
Beyond the financial settlement, UCI and Doctors Care have also entered into a Corporate Integrity Agreement with the Office of Inspector General. This agreement mandates several compliance measures for the next five years. Key requirements include retaining an Independent Review Organization to conduct claims reviews as specified in the agreement and subjecting UCI to routine monitoring by the Office of Inspector General.
Assistant United States Attorneys Brook Andrews and Nancy Cote, along with Special Agent Ryan Schubert of HHS-OIG and Special Agent Doyle Mullis of DCIS, were instrumental in the investigation and negotiation of this settlement. The whistleblowers who initiated the case were represented by attorneys Bert Louthian, John Simmons, Bill Nettles, and Fran Trapp.
The case is formally captioned United States ex. rel. Dove v. UCI Medical Affiliates, Inc., et. al, 2:17-cv-02291-RMG (D.S.C.). It is important to note that the claims resolved by this settlement are allegations, and there has been no formal determination of liability.
