Four defendants in separate, but related, cases pleaded guilty for their roles in a scheme to pay and receive kickbacks in relation to toxicology tests. Mark Rubin, 58, Renee Field, 44, Kelly Nelson, 52, and Carlos Hornedo, 61, were all charged via felony informations in December 2023.
According to the plea documents filed in the case, Ms. Fields was the owner and the Clinical Director at RK Clinical Solutions, LLC. Ms. Nelson was the co-owner of RK. RK sought to financially incentivize medical providers to send tests to RK by providing them with illegal financial incentives that were disguised as legitimate business transactions. Dr. Rubin, a pain management doctor, agreed to submit the majority of his toxicology orders to RK in exchange for kickbacks. He also agreed to order a significant number of toxicology tests to justify the kickbacks. RK was paid by Medicare and other federal healthcare programs in excess of $481,000 and in exchange, Dr. Rubin received over $330,000 in kickbacks. The kickbacks consisted of medical advisor agreement, in which Dr. Rubin would be paid for theoretical advisory services. Dr. Rubin did not perform services sufficient to justify his compensation, was not paid on an hourly rate, and the agreements were used as a way to funnel kickbacks to Dr. Rubin.
In a similar fashion, Dr. Hornedo, a medical doctor, agreed to order certain toxicology tests for patients he saw and ordered the test to be performed by Unified Laboratory Services, LLC and Spectrum Diagnostic Laboratory, LLC. Dr. Hornedo agreed to submit a substantial number of his toxicology orders to Unified and Spectrum in exchange for kickbacks. He submitted orders that resulted in billings by Unified and Spectrum in excess of $4,100,000 to federal healthcare programs. In exchange, Dr. Hornedo received approximately $412,000 in kickbacks, $45,000 in lease payments, $109,000 in medical advisor payments and ownership shares in Reliable Labs, LLC.