The Opportunity Alliance: One Order, a Year of Drug Tests

Whistleblower Justice Network

In the Opportunity Alliance urine testing settlement, the South Portland, Maine, residential provider agreed to pay $346,369 over allegations that misleading requisitions led to excessive drug testing billed to Medicare and MaineCare. The government alleged that individual test orders became a recurring schedule disconnected from residents’ treatment needs. The laboratory sent the bills, but the case followed the decisions that kept the tests coming.

The Department of Justice announced the civil settlement on June 2, 2025. It resolved federal and Maine allegations concerning claims from July 2018 through June 2021. MaineCare is Maine’s Medicaid program.

What Morrison Place Controlled

The Opportunity Alliance operated Morrison Place, a residential treatment program for people experiencing homelessness who had a major mental illness, a substance use disorder, or both. According to the government’s account of its complaint, the organization sent misleading urine drug requisition forms to residents’ medical providers. It then used those forms to direct a separate laboratory to perform the tests.

The requisition was the connection between what a medical provider ordered and what the laboratory would perform. The government alleged that The Opportunity Alliance used that connection to generate testing beyond an individual patient’s needs.

The division of work matters in laboratory billing. The treating practitioner holds the patient’s medical justification for a test. The entity submitting the claim keeps the information it received from that practitioner and documentation showing that the claim accurately reflects it. Those responsibilities are set out in Medicare’s ordering and documentation rules.

A person reading only the laboratory’s bill sees the end of that chain. The Opportunity Alliance case concerns what happened earlier, when the residential provider used the requisition to direct testing. For health care staff familiar with the forms and the treatment program, that is where the allegation becomes recognizable.

How the Standing Schedule Reached Medicare and MaineCare

The government alleged that The Opportunity Alliance treated individual test orders as standing orders for three presumptive and definitive drug tests each week, without exception or regard for individualized treatment needs, for up to a full year. The schedule itself kept producing orders.

Under the arrangement described in the complaint, the third-party laboratory would bill Medicare and MaineCare directly for urine testing performed on Morrison Place clients. It would not bill Morrison Place for any urine-testing-related service. On the government’s account, the program used testing to monitor residents, paid no laboratory bill for it, and left taxpayers paying for tests the residents did not individually need.

The government alleged that the tests lacked individual medical-necessity approval and a valid medical-provider order. It also alleged that The Opportunity Alliance used them for residential monitoring in violation of MaineCare rules. The alleged failure concerned the reason for testing, the authority to order it and the purpose for which the program used it.

When Are Toxicology Tests Unnecessary?

Toxicology tests are unnecessary when they lack a patient-specific medical reason. In this case, the government alleged that a residential monitoring schedule generated tests without individual approval as medically necessary. The question behind each claim was what that resident needed the test for.

The Journal of Family Practice review describes an approach to addiction treatment in which visits and testing become less frequent as addiction behavior diminishes, and more frequent when it increases. Testing frequency follows what is happening with the patient.

The paper puts the tension sharply:

Routine urine drug screening at every visit can make urine tampering more likely and is often unnecessary for stable patients.

Urine Drug Screening: A Guide to Monitoring Tx With Controlled Substances, The Journal of Family Practice, 2021

The paperwork has to carry that individual decision. In its clinical laboratory guidance, the HHS Office of Inspector General says requisition forms should ensure that the ordering provider has made an independent medical-necessity decision for each test the laboratory will bill. It also calls for periodic monitoring, expiration dates and renewal of standing orders. A form intended to keep treatment going can also keep testing going after its justification needs another look.

The Civil Case Followed the Orders

The United States and Maine brought the civil complaint against The Opportunity Alliance under the False Claims Act and Maine’s false claims law. The government alleged that the organization knew its misleading forms were driving false laboratory bills. The people directing the tests could face a case even though another company sent the claims to Medicare and MaineCare.

What Evidence Is Needed to Prove Fraud?

We work with you to establish what the orders and billing records show, and who understood how the testing arrangement operated. An insider can explain how a request for an individual test became recurring laboratory work. That connection drove the government’s allegations here, and it is where our work with you begins.

A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers.

You Know How the Orders Became Routine

If you saw a residential program turn individual orders into automatic laboratory work, talk with our whistleblower experts about the testing you know. We build your case around the connection between the orders, the care and the claims, bring in laboratory fraud whistleblower lawyers who understand toxicology billing, and stay beside you through the case.

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