The District Court for the Middle District of Georgia found in favor of the United States and the State of Georgia in a civil case involving the fraudulent billing of hundreds of TRICARE and Medicaid claims by a Macon healthcare facility, ordering the defendants to pay $9,617,679.22 in damages and penalties. US District Judge Tilman E. “Tripp” Self, III issued the judgment following an evidentiary hearing in US v. Middle Georgia Family Rehab (MGFR) on Tuesday, May 24. The judgment was entered June 2.
US District Judge Self initially granted partial summary judgment in this False Claims Act case on Wednesday, April 20. According to court documents, in that decision, the Court determined that approximately 800 false claims for services were improperly billed to Medicaid and TRICARE by MGFR and MGFR owner Brenda Hicks. Those improper services were billed under the names of a physical therapist and a speech therapist who were no longer employed by MGFR and therefore could not possibly have provided the services in question.
In analyzing the question of whether MGFR knowingly submitted the false claims, the Court found that MGFR’s conduct “epitomizes ‘reckless disregard’ of the truth.” Specifically, the Court found that MGFR’s submission of almost 800 claims to Medicaid and TRICARE over an eight-month period following the resignation of one physical therapist and the submission of 41 claims following the resignation of a speech therapist could not be characterized as an “honest mistake.”