Courtesy Transport Services: Two Settlements, Different Billing Problems

In the Courtesy Transport Services settlement, the company and its two owners agreed to pay $900,000 collectively to resolve allegations that they billed Medicare and Medicaid for ambulance rides patients did not need or never received. A former Courtesy employee brought the whistleblower case. For someone who dispatched the trips, rode with the patients or handled the billing, the difference matters: a ride that should have used other transportation and a ride that never happened leave different contradictions behind the claim.

The Justice Department announced the settlement on July 1, 2025. Courtesy Transport Services, LLC operated in Northeast Florida. The government’s allegations covered basic life support, non-emergency ambulance claims from June 1, 2013, through June 30, 2019.

What the Government Said Courtesy Billed

The government alleged that Courtesy submitted claims for services that were not medically reasonable and necessary, patients who did not require ambulance transportation, or services never actually provided to patients. For an unnecessary ride, the patient may have reached the destination exactly as the trip sheet describes. The issue is why an ambulance was needed. For an unprovided ride, the issue begins earlier: whether the billed transportation happened at all. We would examine different evidence for each, even when both claims used the same billing category.

The distinction also appears at the service level in the government’s First Call Ambulance Service case. There, the government alleged that advanced life support was medically unnecessary on many trips billed at that level, or that First Call had supplied only basic life support. Courtesy’s allegations concerned the need for, or provision of, the transport itself. The service named on a bill has to match both the patient’s need and what the provider furnished.

Does Medicare Pay for Non-Emergency Ambulance Transportation?

Yes. Medicare covers qualifying non-emergency ambulance transportation when the patient’s condition makes another method unsafe and the service meets the other coverage requirements. Under the ambulance coverage rule, the patient’s condition must require both the ambulance and the level of service billed.

The Medicare Benefit Policy Manual makes a distinction familiar to anyone arranging patient transportation. If another method could carry the patient without endangering their health, the ambulance does not become payable merely because that alternative is unavailable. A missing wheelchair van may explain the scheduling problem. It does not explain a medical need for an ambulance.

That is why the patient’s condition on the trip matters so much. A diagnosis or a physician’s order alone does not answer the coverage question. The clinical account must explain why the patient needed this transportation, at this level, when it was provided.

The Documents Behind the Claim

A run report connects the patient’s condition and the care provided to the ambulance bill. The HHS Office of Inspector General’s 2003 guidance for ambulance suppliers identifies the details that belong in that account: dispatch instructions, the patient’s status, why other transportation was unsuitable and why the service level was selected. It also calls for trip times, locations, mileage and services provided.

Those details do different jobs. The clinical narrative explains the need for the ride. The times, locations and services describe what happened. When we examine an allegation of unprovided transportation, we look for the connection between the patient, the trip and the claim submitted for it.

Falsified ambulance run reports can change that account before it reaches billing. The government’s complaint against Hart to Heart Transportation Services alleged that crews were told to record patients lying in bed while omitting their earlier observations of those patients sitting, standing or walking. A crew member may know what the original narrative said. A biller may know what someone demanded it say before submission. The point where those accounts diverge can explain both the false detail and how it entered the claim.

Why a Signed Certification Does Not Settle the Question

An ambulance physician certification statement supports the medical-necessity claim for certain non-emergency trips. That signed statement alone does not establish that the patient needed an ambulance. The Medicare Claims Processing Manual says that a physician’s order does not by itself prove medical necessity and that the service must meet all coverage criteria.

That goes directly to Courtesy’s alleged billing failures. A signature cannot supply a medical need absent from the patient’s condition. Nor can it turn an unprovided ride into a completed transport. The form has to be read with the clinical account and the service actually supplied.

The certification can originate outside the ambulance company. In the Capital Ambulance settlement announcement, the government alleged that Eastern Maine Medical Center personnel supplied incomplete or incorrect medical-necessity information that Capital used to bill Medicare. The person supplying the clinical justification and the company submitting the bill can be different participants in the same claim.

An HHS-OIG report from September 2015 found that claims data did not identify the physicians who certified questionable transports. That finding helps explain the value of an insider who knows where a certification came from and how it reached billing. The payment data alone did not tell that story.

The Owners in the Courtesy Resolution

The Owner Whose Settlement Reflected Ability to Pay

The settlement amounts for Courtesy and one owner were based on their ability to pay, according to the Justice Department announcement. We see the mismatch: the allegations concern what public health care programs paid, while those settlement amounts reflect what the company and that owner could pay.

The Physician Owner in the Same Resolution

The Justice Department identified the other owner as a doctor and included him in the resolution of the transport allegations. For an insider, the useful question is who made which decision: ordering the ride, describing the patient’s condition, supplying a certification or directing billing. We work through those decisions with the person who saw them.

The Separate Emergency-Rate Settlement

Courtesy entered a separate $362,188 settlement with HHS-OIG on July 20, 2016. In that enforcement notice, OIG alleged that Courtesy billed emergency ambulance rates for trips to destinations including skilled nursing facilities and patient residences that should have used the lower non-emergency rate.

That allegation concerned the rate charged for the trip. The later Justice Department settlement concerned whether patients needed ambulance transportation and whether services were provided. The earlier settlement fell within the period covered by the later allegations. Those allegations reached beyond that settlement, into 2019.

What Evidence Is Needed to Report Fraud?

For the practices described here, useful evidence connects the patient’s condition, the transport actually provided, the documentation and the bill. Your part may be the dispatch record, the original run report, a certification or an instruction to change the account. We work with you to understand what that part shows and how it fits the claim.

Courtesy’s case began with a former employee’s qui tam lawsuit, and the settlement announcement provided for that employee to share in the proceeds. A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers.

You Know the Trip Behind the Bill

If you worked at Courtesy or recognize these practices in your own ambulance operation, tell our whistleblower experts where the trip and the bill part company. We build the case with you and bring in ambulance fraud whistleblower lawyers who understand medical necessity, transport records and billing decisions. You have partners who stay beside you from that first conversation through the case.