Foundations, Olympia and Tridia: Three Allegations Behind One Settlement

The Foundations, Olympia and Tridia fraud case led to an approximately $19.5 million settlement over allegations of unnecessary therapy, ineligible hospice care and home-health referral kickbacks. Each allegation points to a different decision inside the business: how much treatment to deliver, who qualified for a benefit, and where to send the next patient. The therapy allegation meant residents received treatment they did not need, at taxpayers’ expense.

The Justice Department announced the resolution on July 17, 2017. Ohio-based Foundations Health Solutions Inc., Olympia Therapy Inc. and Tridia Hospice Care Inc. settled alongside two executives who partly owned or controlled the companies between 2008 and 2013. As part of the settlement, Foundations and one of those executives entered into a five-year Corporate Integrity Agreement with the Office of Inspector General of the Department of Health and Human Services. Former Olympia and Tridia employees brought the qui tam cases.

Provider Services Became Foundations

Provider Services became BCFL in 2010 and Foundations Health Solutions in 2013. The earlier company name appears in the cases behind the settlement. Someone who remembers Provider Services and someone searching for Foundations can be looking at the same company’s history.

Unnecessary Therapy in the RUG Era

The government alleged unnecessary therapy at 18 homes from January 2008 through December 2012. The question inside that allegation is whether the treatment reflected the patient’s needs or the payment the business wanted to generate.

Those dates place the conduct under Medicare’s historical RUG-III and RUG-IV payment systems. Therapy minutes, the disciplines providing treatment and assessment dates helped determine the payment classification. Under the RUG-III assessment instructions, the Ultra High therapy band began at 720 minutes a week, with additional requirements about treatment days and disciplines. A treatment schedule therefore had a financial consequence as well as a clinical one.

Medicare’s Patient Driven Payment Model replaced RUG-IV on October 1, 2019. The therapy allegation here concerns the earlier system, when the minutes recorded during an assessment period helped set the rate.

For a therapist or assessment coordinator, the connection runs from the order and treatment notes to the minutes reported and the resulting claim. The staff member who knows why a schedule changed can explain something the final total of minutes cannot.

Hospice Eligibility Was a Separate Allegation

The government alleged that from April 2011 through December 2013, Tridia billed Medicare for hospice services to patients who were ineligible for the Medicare hospice benefit because Tridia failed to conduct proper certifications or medical examinations. That puts the clinical account of the patient beside the eligibility representation supporting payment: what staff observed, what the care records said and what the company billed.

Hospice and nursing-home therapy can also intersect through the bill itself. In the American Senior Communities settlement announced in 2022, the government alleged that the facility operator billed Medicare separately for therapy that the residents’ hospice benefit should have covered. There, the alleged problem was billing for a service already covered by another benefit. Here, the hospice allegation concerned eligibility for the benefit itself.

Home-Health Referral Kickbacks Involving Amber

The home-health allegation was that from January 2008 through December 2012, the two executives solicited and received kickbacks to refer patients from skilled nursing facilities managed by Provider Services or BCFL to Amber Home Care LLC, a home health care services provider. Its central question is what someone received in exchange for directing a patient to a provider.

Referral relationships deserve attention because they can explain a pattern that billing totals alone leave obscure. The National Bureau of Economic Research’s 2026 working paper Medicare Home Health Fraud: How Much, Where, and Who? describes a combination of referral concentration, repetitive care and patient characteristics among the agencies it classified as fraudulent:

The finding gives an insider a useful way to describe what they saw: who repeatedly sent patients, what services followed and how those services matched the patients’ conditions.

A referral benefit can also take the form of work supplied for free. In the HPH Hospice settlement announced in 2013, the government alleged that the hospice provided free services to skilled nursing facilities in exchange for referrals. That separate case shows why a referral inquiry follows both money and services. The bargain may sit in a service arrangement while the revenue arrives through patient claims.

What Evidence Is Needed to Prove Fraud?

Our whistleblower experts connect what you know about the care or referral to the claim and the people who controlled it. That can mean following a treatment decision across company lines.

The company submitting the bill may also depend on another company’s work. In the Kindred/RehabCare therapy settlement announced in 2016, the government alleged that a therapy contractor caused facilities to submit inflated claims. The alleged practices included automatically placing patients in the highest payment category, timing treatment to payment thresholds and reporting services that staff never delivered. Separate customer settlements addressed alleged failures to prevent those practices. That is why we follow the instruction, the documentation and the bill across company lines.

A healthcare employee may see the treatment decision. Someone in finance may see a contract or payment. Our work is to connect that knowledge to the representation the government paid for and the person who controlled it.

What Is the Reward for a Medicare Fraud Whistleblower?

A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers. In this resolution, the Justice Department announced approximately $2.9 million for the action brought by the former Olympia employee. It also announced a separate collective award for the former Tridia employees.

Those employees brought knowledge from different parts of the health care business. The case shows why the person who recognizes the therapy problem and the person who understands the hospice records can each have something substantial to contribute.

You Know How the Care Became a Claim

If you saw therapy schedules, hospice decisions or referral payments that tell a different story from the bills, speak to one of our whistleblower experts about how the care became a claim. We build your strongest skilled nursing facility whistleblower case with you and bring in skilled nursing facility whistleblower lawyers who understand the therapy, hospice and home-health connections. You have a partner from the first account of what happened through the pursuit of a recovery.