Circle of Life Transition Center: Psychotherapy Allegedly Billed Under a Licensed Counselor’s Name

In the Circle of Life Transition Center fraud case, the Hartford practice and its licensed counselor owner agreed to pay $45,488 to settle allegations that they billed Medicaid for unlicensed workers’ psychotherapy as the owner’s own services. The settlement covered conduct from January 1, 2014 through April 5, 2017. A bill can carry a licensed counselor’s name while telling a false story about who delivered the care.

The U.S. Attorney’s Office for the District of Connecticut announced the civil settlement on October 3, 2019. It resolved federal and state False Claims Act allegations against both the owner and Circle of Life Transition Center.

What Medicaid Was Told About the Psychotherapy

The government alleged that Circle of Life’s owner billed Medicaid as though she had personally provided psychotherapy that unlicensed individuals actually delivered.

Circle of Life was a private behavioral health practice in Hartford, Connecticut. Its owner was a state-licensed professional counselor enrolled as a Licensed Behavioral Health Clinician in Independent Practice in the Connecticut Medical Assistance Program, which includes Medicaid.

An appointment can appear on the schedule while the claim tells a different story about who provided it. The question is who was in the room, and whose work Medicaid was asked to pay for.

Why the Name on the Claim Matters

The payment rule cited in the settlement announcement required the enrolled provider to perform the services. The Justice Department pointed to the Connecticut Department of Social Services’ provider manual for licensed behavioral health clinicians in independent practice: the department would not pay for services supplied by anyone other than the provider.

We see a simple wrong in that allegation: Medicaid was asked to pay for a professional qualification the treating worker did not hold. A license on paper. Patients depended on the person in the room.

The identity of the business alone does not answer who performed the treatment. In a credential-fraud inquiry, the connection between the worker, the qualification and the claimed service is the point.

The Settlement Covered the Practice and Its Owner

As part of the civil settlement, the owner also accepted a voluntary seven-year suspension from the Connecticut Medicaid Program.

The case grew out of a broader behavioral health investigation by the U.S. 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.

What Evidence Is Needed to Prove Fraud?

For a psychotherapy provider-identity case, the evidence connects the claim to the service date, the actual treating worker, that worker’s qualifications and the treatment record. We examine how those pieces fit together and what the people responsible for billing knew about the difference.

That is where knowledge from inside a practice matters. A worker familiar with the appointments may recognize a name that does not match the person providing treatment. Someone familiar with billing may understand how that name reached the claim. We work with you to connect that knowledge to the particular Medicaid services at issue.

A separate whistleblower complaint against Connex Family Services shows how stark a mismatch can become. The whistleblower alleged that a conversation with the person named on a treatment plan revealed that he did not know the patient:

A treatment plan bearing a name and the named person’s account of the patient told different stories, according to that complaint. The conversation supplied something the document alone could not: whether its apparent author recognized the care attributed to him. The complaint separately alleged bills for services that had already been billed or had never been performed.

The Connecticut Pattern in Unlicensed Psychotherapy Billing

Other Connecticut settlements show the same provider-identity problem and how it can overlap with false descriptions of the treatment itself.

In the Today’s Youth settlement announcement, the government alleged that Medicaid claims presented services as the work of licensed clinicians when unlicensed providers delivered them. The release addressed supervision directly: supervising an unlicensed person did not satisfy that independent-practice program’s requirement about who rendered the care.

The K-Assist civil settlement likewise concerned allegations that psychotherapy by unlicensed individuals had been billed as services rendered by licensed providers.

The Behavioral Management settlement shows why the worker’s qualification is one part of the comparison. The government alleged that claims represented 45-minute individual psychotherapy with biofeedback by licensed staff, while the actual services were 20-minute groups without biofeedback, delivered by unlicensed personnel.

That allegation changed the person, the duration and the treatment described to Medicaid. A review limited to the clinician’s name would miss the shorter session and the group format. A review limited to attendance would miss the claim’s description of licensed individual care. The employee who knows how the appointments ran can bring those differences into view.

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. For someone who recognizes a provider-identity mismatch in Medicaid psychotherapy billing, we assess how their knowledge can support a whistleblower case and bring in Medicaid whistleblower lawyers who know behavioral health billing.

You Know Who Did the Work

If you know whose name went on the Medicaid claim and who actually treated the patient, talk with our whistleblower experts about that difference. We work alongside you to build your strongest Medicaid whistleblower case and bring in healthcare fraud whistleblower lawyers who understand psychotherapy billing and provider qualifications. From the first conversation, you have experts on your side who know how to connect the treatment, the claims and the decisions behind them.