Compassionate Counseling Services: Backdated Assessments Behind Follow-On Medicaid Claims

The Compassionate Counseling Services fraud case produced a $150,000 civil settlement over allegations of improperly billed and backdated North Carolina Medicaid diagnostic assessments. The governments alleged that the missing signed assessments also left later treatment claims without documentation supporting medical necessity. For someone who knows when an assessment was actually signed, the significance reaches beyond that document to the services billed after it.

Compassionate Counseling Services, LLC provided behavioral health care in Rockingham, North Carolina. The United States and North Carolina alleged that it submitted improper claims for diagnostic assessments and for services following those assessments from June 7, 2016 through January 8, 2021. Compassionate denied the allegations and agreed to pay to settle them.

The Assessment That Supported the Next Medicaid Claim

A diagnostic assessment served as the initial order establishing medical necessity for certain treatment services under the North Carolina Medicaid requirements described in the U.S. Attorney’s settlement announcement. An authorized professional had to sign and date it. That made the assessment part of the basis for billing the care that followed.

The governments alleged that Compassionate employed only one professional authorized to supply those signatures. That professional worked on site only on the third Friday of each month and, according to the governments, could not have provided the required signatures until then.

The alleged problem ran through both the assessment claim and the later treatment claims. The governments said Compassionate billed for assessments without maintaining properly signed and dated versions, and improperly backdated assessments. They alleged that the company consequently lacked documents supporting that the assessments had been properly rendered as claimed.

For the follow-on services, the allegation was equally specific: Compassionate could not support medical necessity where the preceding assessment had been improperly billed without the required professional’s signature.

We would not dismiss the alleged backdating as catch-up paperwork. The clinical approval has a date, and the claims depend on what that approval supports. Putting an earlier date on the paperwork changes the story the file tells about the basis for treatment.

Why the Signature and Date Mattered

The authorized signer’s schedule gave the governments a concrete way to test the assessment dates. Their allegation connected when that person could provide a signature with what Compassionate’s files and claims represented.

In behavioral healthcare, treating a patient, signing the initial order and submitting the claim can fall to different people.

That division of work explains why someone inside the office may see something a claim alone cannot show. A worker handling assessments may know which documents were waiting for a signature. A billing employee may know which services the provider had already claimed. The authorized professional may know when a document actually reached them. Each view can help explain the sequence behind the file’s dates.

Our examination follows that sequence: the assessment, the actual signature date, the treatment dates and the associated claims. Original timestamps, staff schedules and instructions about changing records can show how the file came to tell its story.

The Civil Settlement and the Whistleblower Opportunity

The U.S. Attorney’s Office for the Middle District of North Carolina announced Compassionate’s agreement on May 17, 2023. The company agreed to resolve civil claims under the federal and North Carolina False Claims Acts concerning its Medicaid billing. The U.S. Attorney’s Office for the Middle District of North Carolina and the Medicaid Investigations Division of the North Carolina Attorney General’s Office investigated the matter.

The settlement brought the alleged documentation failure into a false-claims case: the governments challenged what the provider billed and the support for those bills.

A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers. If you know how assessment dates or signatures were changed to support Medicaid claims, our whistleblower experts can examine that connection with you.

Backdated Treatment Plans in the Journey Case

In the Journey to Hope Health and Healing case, the government complaint alleged that counselors backdated treatment plans for an accreditation audit, including plans copied from other patients.

You Know When the Assessment Was Signed

If you handled assessments, signed clinical orders or billed the care that followed, talk with our whistleblower experts about the dates and decisions you saw. We build your Medicaid whistleblower case around that inside knowledge and bring in Medicaid fraud whistleblower lawyers who understand behavioral health records and payment requirements. We stay beside you through the case, bringing our judgment and expertise to the decisions ahead.