Children’s Behavioral Therapy: Short Sessions Billed as One-Hour Psychotherapy

In the Children’s Behavioral Therapy fraud case, the practice and its licensed professional counselor owner agreed to pay $39,471 to resolve allegations that the counselor billed Connecticut Medicaid for one-hour individual psychotherapy sessions that were shorter. For someone who saw the sessions and the claims, the question is concrete: how did the time delivered become the time billed?

Children’s Behavioral Therapy LLC was a private behavioral health practice in Waterbury, Connecticut. Its owner was enrolled as a Licensed Behavioral Health Clinician in Independent Practice in the Connecticut Medical Assistance Program, which includes Medicaid. The U.S. Attorney’s Office for the District of Connecticut announced the civil settlement on January 24, 2020.

Shorter Sessions, Longer Claims

The government alleged that the counselor repeatedly billed Medicaid for an hour of one-on-one psychotherapy while performing less time. The settlement covered conduct from November 3, 2014 through March 15, 2017. The settlement amount covered that period of allegedly inflated claims, not a single disputed appointment.

That makes this a useful psychotherapy time fraud case for an insider. The government described sessions the counselor actually performed. A visit could be real, a patient could receive care, and the bill could still claim more treatment time than the counselor delivered.

We see the absurdity in the allegation: the appointment ends, but the billed time keeps going. The employee who knows when treatment ended may see something the claim alone cannot show.

Why Psychotherapy Minutes Matter

Psychotherapy codes distinguish the time spent treating a patient. The treatment notes need to account for those minutes, not just the appointment slot on a calendar.

For a separate Medicare example, First Coast’s psychotherapy coding guidance effective January 1, 2025 uses 90832 for 16 through 37 minutes, 90834 for 38 through 52 minutes, and 90837 for at least 53 minutes. It requires start and stop times or total psychotherapy time, excluding time spent on a separate evaluation and management service.

That is a later Medicare example. The Children’s Behavioral Therapy case concerns earlier Connecticut Medicaid claims.

For a whistleblower who has seen 90837 billed for short therapy sessions, the valuable knowledge is what happened during the visit and how that work became a claim. We examine the applicable payment rule alongside the treatment record and billing decisions.

The Connecticut Settlement Covered the Practice and Its Owner

Children’s Behavioral Therapy and its owner entered the agreement with both the federal and state governments to resolve allegations under their False Claims Acts. The owner also accepted a voluntary five-year suspension from Connecticut Medicaid as part of the civil settlement.

The case arose from a broader behavioral health investigation conducted jointly by the Department of Health and Human Services Office of Inspector General, the Chief State’s Attorney’s Medicaid Fraud Control Unit and the Connecticut Office of the Attorney General. The Connecticut Department of Social Services supported the investigation.

What Are Some Examples of Unethical Billing Practices in Counseling?

Inflating session time, adding a service that was never performed and billing under a clinician who did not deliver the care appear in separate counseling cases.

A Shorter Session Became a Longer One

In a whistleblower’s amended complaint involving Turning Point Care Center, Inc., the alleged difference was visible in a particular session and its billing code. The complaint put the actual treatment and the Medicare claim side by side:

The same complaint separately alleged that a psychotherapy session was billed with an additional evaluation service that had not been provided. These are different ways to enlarge a claim: more time for the service, or another service on top of it. Both allegations depend on knowing what the patient actually received.

That is the close parallel to Children’s Behavioral Therapy. An account of the encounter can expose the difference between care delivered and care billed, even when the patient attended and a clinician provided psychotherapy.

A Group Became Individual Therapy

In the Connecticut case involving Behavioral Management LLC, the government alleged that claims under code 90876 represented 45-minute individual psychotherapy with biofeedback by licensed staff, while the services were 20-minute groups without biofeedback, delivered by unlicensed personnel. Behavioral Management and its owner agreed to a $100,842 settlement for the alleged conduct.

Time was one part of that mismatch. The claim also represented individual treatment, a particular treatment method and a licensed provider. Someone who attended the group or knew the staffing could explain facts that the code obscured.

The Clinician on the Claim Was Different From the Worker

Circle of Life Transition Center supplies another Connecticut comparison. The government alleged that unlicensed individuals’ psychotherapy was billed as the licensed counselor’s own services. The counselor and practice agreed to settle for $45,488. The relevant question there was who performed the work.

These cases show why we examine time, service type and the treating worker separately. Children’s Behavioral Therapy’s alleged mismatch was the length of the counselor’s own sessions.

What Evidence Does a Whistleblower Need?

For inflated psychotherapy time, we work with an insider to connect the claim to what happened in the session. Treatment notes, schedules and billing records can tell different parts of that story.

An insider in a health care practice may know the treatment side, the billing side or the decisions connecting them. A therapist may know how the session was documented. A billing employee may know which code went onto the claim. A scheduling employee may know how the appointments fit into the working day. We work with that view of the practice and test how it fits the other evidence.

How Much of a Settlement Does a Whistleblower Get?

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

You Know When the Session Ended

If you saw short psychotherapy sessions become longer Medicaid claims, speak with our whistleblower experts about how the hours were billed. We build your strongest case around your knowledge, bring in behavioral health fraud whistleblower lawyers who understand timed-service billing, and stay beside you as the case moves forward.