Hospice Provider Pays $4 Million to Settle Allegations of Fraudulent Billing

February 19, 2015 | By Lawrence J. Tabas

Good Shepherd Hospice, Inc., a for-profit hospice providing services in Oklahoma, Missouri, Kansas, and Texas (“Good Shepherd”), has agreed to pay $4 million to the U.S. government to settle allegations that it submitted false claims for hospice patients who were not terminally ill. Good Shepherd has also agreed to enter into a five-year corporate integrity agreement with the U.S. Department of Health and Human Services, Office of the Inspector General.

The government alleged that Good Shepherd engaged in the following actions:

  • knowingly submitted or caused the submission of false claims for hospice care for patients who were not terminally ill;
  • engaged in certain business practices that contributed to claims being submitted for patients who did not have a terminal prognosis of six months or less, by pressuring staff to meet admissions and census targets and paying bonuses to staff, including hospice marketers, admissions nurses and executive directors, based on the number of patients enrolled;
  • hired medical directors based on their ability to refer patients, focusing particularly on medical directors with ties to nursing homes; and
  • failed to properly train staff on the hospice eligibility criteria.

According to the U.S. Department of Justice press release, “[w]hen a Medicare patient receives hospice services, that individual is no longer entitled to Medicare coverage for care designed to cure his or her illness.”

This matter was brought to the attention of the U.S. government by two former employees of Good Shepherd, who filed suit under the whistleblower provisions of the False Claims Act. These individuals will receive approximately $680,000.

To read the U.S. Department of Justice press release, click here.

To read the Corporate Integrity Agreements, click here and search for “Good Shepherd” in the “Complete CIA List.”

About the Authors

Lawrence J. Tabas


Lawrence is the Chair for Obermayer’s Health Care Law Department and Election Law Practice Group. Lawrence’s Health Care Law legal experience includes the representation of Pennsylvania County governments in Behavioral Health Managed...

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