Connections Community Support Programs: The Clinician in the Drop-Down Menu

The Connections Community Support Programs fraud case led to an agreed $13,757,520 False Claims Act judgment over allegations that the Delaware provider billed Medicare and Medicaid using false clinician identities and qualifications, and incorrect Medicaid procedure codes. The government had alleged more than $4,500,000 in improper payments for those services before Connections agreed to the larger judgment.

The whistleblowers’ complaint described a billing system that allegedly required staff to select a designated clinician before a claim could go out. The person chosen from the menu, they alleged, had neither delivered nor supervised the care.

Connections provided mental health and addiction treatment across Delaware. Two former employees brought the whistleblower case, and the United States joined part of it in April 2021. The agreements announced that August addressed the health care billing allegations and a separate controlled-substance recordkeeping case. By then, Connections had filed for bankruptcy and sold its operations.

The Qualifications on the Claim Changed the Payment

The government alleged that Connections used the identity of an eligible professional to obtain payment for work done by someone who lacked the required qualification. In Medicare, that determined whether the service could be reimbursed. In Delaware Medicaid, the rendering provider’s qualification also affected the rate.

The Justice Department’s April 9, 2021 announcement described more than 4,000 allegedly false Medicare claims from at least January 2015 through October 2019. It also alleged more than 250,000 false Medicaid claims that misrepresented the rendering provider’s license or education level and produced full or partial overpayments.

The August agreement also addressed Medicaid procedure codes that were incorrect for the person performing the service and produced higher payments. The alleged substitution therefore reached both the identity on the claim and the price charged for the care. The government alleged that taxpayers paid for qualifications the worker in the room did not have.

The Clinician Selected Before the Claim Went Out

The whistleblowers’ first amended complaint described how staff allegedly changed that identity inside Connections’ electronic records. The system initially filled the billing field with the name of the person entering the information. Management allegedly instructed staff to replace it:

According to the complaint, if a provider failed to replace the automatically populated name with the designated clinician, billing staff and CareLogic would reject the claim before it reached the managed care organization. The complaint alleged that Connections required a licensed clinical social worker in that field even when the social worker had neither provided nor supervised the service. The alleged control was built into the route from a treatment note to an insurer’s bill.

The complaint connected the selection to paid claims. One whistleblower alleged that a Health Options payment statement for the Harrington clinic contained approximately 651 improper uses of their NPI, the provider identifier attached to the claims. The whistleblower also alleged that their identifier appeared on claims from locations where they were neither working nor supervising at the relevant time.

That account connects a management instruction, a software field, the clinician’s actual work and the payer’s statement of claims paid.

Records Completed to Fit the Billing

The whistleblowers also alleged that Connections filled gaps in clinical records with accounts that did not reflect the care provided. The complaint described an employee with administrative access completing a physician’s unfinished records without consulting him or having notes about the relevant visits. It alleged that another employee had to use the physician’s login credentials to fabricate more than 1,400 unfinished records.

The problem reached the clinician asked to approve the resulting account. In one example, the complaint said a record described treatment for conditions when the underlying record called for referral to a specialist. The whistleblower objected:

The complaint further alleged that Connections rushed to complete documentation before external audits regardless of whether the finished records reflected actual services. One whistleblower described clinical and billing audits conducted separately, without comparing the treatment records against the reimbursement claims.

A completed chart could tell an auditor a different story from the one the treating employee remembered. The request for a signature asked a clinician to stand behind that account.

A Treatment Day and a Billed Service Are Different Facts

The complaint’s allegations extended beyond whose name appeared on a claim. They also concerned how Connections turned time at a clinic into billable services. Behavioral health payments can attach to a timed service, a group session or a program day. The unit being billed determines which work the claim represents.

At Harrington, the whistleblowers alleged that a fast-track program obtained reimbursement for 23 hours of services even when Connections provided only four. They also alleged that Connections separated intensive outpatient services into individual bills to avoid a nine-hour weekly minimum.

A similar combination of representations appeared in the government’s case against Behavioral Management. The Connecticut provider allegedly billed for 45-minute individual psychotherapy with biofeedback by licensed staff while delivering 20-minute groups without biofeedback through an unlicensed person. The code represented time, treatment format, a particular therapy and a qualified clinician together.

At Connections, the alleged identity selection and record fabrication make those same comparisons concrete. Knowing that a patient attended the clinic answers only part of the question. The claim also says what service occurred and whose qualifications supported payment.

The Separate Methadone and Buprenorphine Judgment

Connections also agreed to a separate $1,621,571 civil judgment over Controlled Substances Act allegations, smaller than the billing judgment. The government alleged that the company negligently failed to keep proper records of methadone and buprenorphine used in substance use treatment, and transferred controlled substances between locations without proper documentation.

Someone who knows how medication moved between clinics may see a different problem from the employee who knows whose name was selected for billing. Both concern what the organization recorded about its work, and Connections agreed to separate civil judgments to address them.

The Agreements Followed Bankruptcy and an Asset Sale

Connections filed for bankruptcy on April 19, 2021. On June 15, it sold its assets and operations to Conexio Care and Coras Wellness and Behavioral Health, which took over the treatment services.

When the agreements were announced on August 26, 2021, both still required bankruptcy court approval. The judgment amounts were agreed sums, not reported collections; the government’s eventual recovery depended on the funds available in the bankruptcy estate to pay it and other creditors.

What Evidence Is Needed to Prove Fraud?

Evidence connecting the paid claim to the work actually performed is central to a healthcare billing case like Connections. Its complaint illustrates those connections through a billing menu, a claim-rejection rule, a provider payment statement, unfinished records and requests for signatures.

The employees’ allegations connect management’s instructions to the clinician selected for billing, then to the payer’s statement. Their account of unfinished records also connects the person completing a chart to what that person knew about the visit. Those are the gaps between a clinic’s work and its claims that an insider can help our experts examine.

Our whistleblower experts work with insiders to connect that operational knowledge to the government payment and the decisions behind it. A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers.

You Know Who Delivered the Care

If you saw a clinician selected for work they never performed, or records completed to justify a bill, talk with our whistleblower experts about what happened inside the clinic. We build the case with you, bring in behavioral health fraud whistleblower lawyers who understand rendering identities and treatment billing, and stay alongside you through the case.