Med First Immediate Care & Family Practice, PA (Med First) has agreed to pay the government $1,450,000 to resolve False Claims Act allegations that its clinic in Dillon, South Carolina had been operating as a pill mill and falsely filing claims to Medicare and Medicaid for medically unnecessary urine drug testing (UDT), as well as lengthy and complex office visits that were not performed. The United States and the State of North Carolina alleged that between January 1, 2015, and August 15, 2019, Med First, through its Dillon clinic, knowingly submitted or caused to be submitted claims to Medicare and Medicaid for presumptive and definitive UDT that were not medically reasonable or necessary. Presumptive UDT are tests that screen for the presence of drugs, and definitive UDT are tests that identify the concentration of those drugs in a patient’s system. The government contended that Med First performed both of these tests at nearly every patient office visit for patients on opioid therapy, and that the majority of patients at the Dillon clinic were receiving opioids during the relevant time period. Med First performed the repetitive testing without conducting individualized determinations of need or risk profile. In addition, the results of the UDT were often disregarded as the opioid prescription rarely altered despite unexpected UDT results.
The United States and the State of North Carolina further alleged that Med First billed for office visits, known as Evaluation and Management (E/M) services, at higher levels of complexity than actually provided to patients. There are five levels of E/M services, and the higher the level billed, the more complex and often lengthier the office visit must be. The government alleges that the Dillon clinic provider did not engage in complex office visits when spending little time with patients and simply refilling opioid prescriptions.
