STG Healthcare of Atlanta: Enrollment Targets and a Backup Medical Director

In the STG Healthcare Atlanta settlement, STG and two senior executives agreed to pay $1.75 million over allegations of enrolling ineligible hospice patients and paying for physician referrals. The company operated as Interim Healthcare of Atlanta. Its former employees described the pressure behind the claims: fill the census, keep patients enrolled, and make the clinical record support another paid day.

The Department of Justice announced the settlement on March 4, 2020. The government alleged that, from 2013 through 2017, aggressive enrollment goals and inadequate supervision of admissions produced false Medicare and Medicaid health care claims. Two former employees brought the hospice fraud case under the False Claims Act. Their complaint describes an Atlanta operation where the admission target reached into the nurse’s notes, the physician’s certification and the discharge decision.

The Enrollment Target Reached Back to Discharged Patients

The complaint alleged that STG’s owners wanted 100 patients on the census by midnight on December 31, 2015. Management’s proposed source of new admissions included people the hospice had already discharged for failing to qualify:

The complaint also alleged admission bonuses for marketers, a bonus for the highest monthly admissions, and offers of extra mileage reimbursement and gift cards for nurses who completed admissions by a deadline.

The payment system explains the value of a full census. Medicare pays routine hospice care by the enrolled day, whether or not a visit occurs that day. The Office of Inspector General’s January 2015 study, Medicare Hospices Have Financial Incentives to Provide Care in Assisted Living Facilities, put the broader incentive plainly:

In STG’s case, the complaint alleged that staff admitted patients to watch whether they would decline, keeping them through an initial benefit period to collect reimbursement. In that account, enrollment came first, and staff waited for the illness to justify it.

The recruitment allegation also reached what families were told. The whistleblowers alleged that marketers targeted poor Black residents in particular Atlanta ZIP codes, promised extra help, and avoided explaining that the service was hospice when obtaining consent. A family looking for help at home was allegedly being sold an enrollment whose meaning had been withheld.

Medicare hospice enrollment means choosing comfort care in place of curative treatment for the terminal condition. Concealing that choice would take more than money from taxpayers: it would deny patients a say in their own care.

Do Doctors Get Kickbacks for Referrals?

Physician referral kickbacks were part of the STG allegations. The government alleged that STG paid a referring physician to be a backup medical director who did not serve as a legitimate hospice physician. Medicare and Medicaid claims for patients referred through that arrangement were part of the settlement.

The complaint separately described an expensive gift to a referring physician and instructions for the office manager to obtain patients from that physician’s office when the census was low.

For someone inside the hospice, compensation records and referral activity tell one part of the story. The clinical work behind the title tells another. We examine those together: what the physician was paid to do, what work the physician actually performed, and which patient admissions followed.

Who Determines Eligibility for Hospice?

A physician certifies the terminal prognosis that supports Medicare hospice eligibility. The benefit requires a life expectancy of six months or less if the illness runs its normal course, and subsequent benefit periods require recertification by a hospice physician. The physician’s narrative must reflect the patient’s individual clinical circumstances.

The complaint alleged that STG’s previous medical director was replaced after discharging patients he considered inappropriate for hospice. His replacement allegedly instructed nurses to admit or retain patients and watch for decline. It also alleged that administrators ignored nurses’ notes, patient records and lab work, then fabricated information so the medical director would admit or recertify patients.

Those allegations show how admission and recertification decisions can be shaped before the physician signs. The nurse’s observation and the packet put before the physician may tell different stories. The person who saw both can explain who changed the account and why.

How Do You Document Decline in Hospice Patients?

The clinical account must reflect the individual patient’s condition. In STG’s case, the whistleblowers alleged that managers instructed staff to chart decline while leaving out improvement, even when improvement accurately described the patient.

The complaint alleged that administrators signed nursing visit notes in a whistleblower’s name even though she had never seen the patient.

The alleged rewriting also followed outside scrutiny. When Georgia requested nursing notes and certifications of terminal illness for 15 patients, the complaint said files lacked documentation. A clinical manager allegedly said the missing notes and certifications would be created, and an office manager was to obtain a physician’s signatures for submission to the state.

For a claim supported by an altered chart, the comparison is between what the clinician observed and what management wanted recorded. In these allegations, the chart was being made to fit a payment decision already taken.

Keeping Patients After a Discharge Decision

The complaint alleged that STG prolonged stays through a sequence of reviews after a nurse questioned eligibility for recertification. A joint visit, a nurse practitioner’s assessment and an interdisciplinary meeting stood between that concern and a discharge order. The whistleblowers said the process kept revenue coming from patients who no longer qualified.

One patient example went further: a medical director had already found the patient inappropriate and written a discharge order, but the nursing director allegedly instructed the case manager to keep the patient on service to preserve census and revenue. The alleged instruction overrode a discharge decision already made.

A similar admission practice appeared in the complaint against Good Shepherd Hospice. Its whistleblowers alleged that an observation period allowed enrollment of patients already found ineligible, and that medical directors’ continued employment depended on bringing in referrals. Both complaints describe the same alleged pressure: make the clinical decision serve the census.

What the Atlanta Records Show an Insider

The STG case connects records that different employees encounter in different parts of the business. Nurses see the patient and the visit note. Admissions and marketing staff see census targets and recruitment incentives. Medical directors see certification material, while billing staff see the claims that follow.

We work with hospice whistleblowers to connect the clinical account, management’s instructions and the payment records into a case. A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers.

When the Census Target Overruled the Clinical Record

If you saw enrollment pressure change a patient assessment, a certification or a discharge decision, speak with our whistleblower experts about the pressure behind those decisions. We build your strongest hospice whistleblower case with you and bring in hospice fraud whistleblower lawyers who understand clinical eligibility, referral payments and the claims they produce. We stay beside you as that inside knowledge becomes the foundation of your case.