Golden Living GGNSC: Two Nursing Homes Accused, Six Under Monitoring

GGNSC Holdings agreed to pay $613,300 in the Golden Living GGNSC fraud case over allegations that it billed government programs for inadequate and worthless wound care at two Atlanta-area nursing homes. Its resolution also reached beyond the accused homes, putting a wider group of facilities under independent monitoring.

What Golden Living Was Accused Of

The government alleged that Golden Living submitted false claims to Medicare, Medicaid and the Veterans Administration for wound care from January 1, 2006 through May 31, 2011. The Justice Department’s account tied the claims to inadequate and worthless monitoring, documentation, prevention and treatment of residents’ wounds.

Residents needed wound care, and public programs paid for it. The government alleged that Golden Living billed those programs for care so inadequate it was worthless. The bill described a service the residents depended on. The allegation challenged what they actually received.

Medicare’s bundled skilled-nursing payment includes nursing and supplies, as the CMS claims manual explains. That puts the facility’s claim for the resident’s stay alongside the wound-care notes: the nursing is part of what Medicare pays the home to provide. A nurse may know what happened at the bedside while a billing employee sees the claim sent for payment.

Medicare pays the facility, and the facility’s contract determines payment to an outside supplier. Nursing home care can involve outside staffing and service vendors as well as the home’s own employees. For an insider, the account of who provided the care may therefore extend beyond the people on the facility’s payroll.

The California Research Bureau’s 1997 report, Fraud and Abuse in the Health Care Market of California, described a category of health care fraud and abuse that focuses on repeated failures in delivery:

In the Golden Living allegations, documentation sat alongside prevention and treatment. The government challenged both the care and the account of it.

Which Company and Which Nursing Homes?

GGNSC Holdings, LLC operated nursing homes under the Golden Living name. The company was based in Plano, Texas, and the wound-care allegations concerned Golden LivingCenter–Glenwood and Golden LivingCenter–Dunwoody in the Atlanta area. Dunwoody had previously been called Golden LivingCenter–Northside.

The Settlement and the Whistleblower’s Share

The Justice Department announced the civil settlement with the United States and Georgia on January 2, 2013. It resolved some claims in a qui tam case brought by a whistleblower. The federal allegations arose under the False Claims Act, and the settlement also addressed Georgia’s State False Medicaid Claims Act.

The announcement said that the whistleblower would receive a share of the settlement payment resolving those claims.

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

What the Monitoring Agreement Changed

Golden Living’s corporate integrity agreement extended oversight to six Atlanta-area facilities. Along with Glenwood and Dunwoody, it covered Golden LivingCenter–Briarwood, Golden LivingCenter–Decatur, Golden LivingCenter–Kennestone and Golden LivingCenter–Medical Arts. The agreement reached beyond the homes accused of inadequate wound care.

GGNSC signed the agreement with the Department of Health and Human Services’ Office of Inspector General. The facilities had to continue implementing policies and procedures for compliance with patient-care requirements. An independent monitor was appointed to oversee operations for up to five years, checking whether those policies worked and whether patients received appropriate care.

What Evidence Is Needed to Report Fraud?

For a wound-care billing case, the useful evidence connects the resident’s needs, the care actually delivered, the documentation and the government claim. Our whistleblower experts work with insiders to understand those connections and the decisions behind them.

Nursing notes, wound orders and treatment records describe the care behind the resident assessment and the bill. The Minimum Data Set draws on clinical observations and contributes to payment classification, care planning and quality measurement. A nurse, an assessment coordinator and a healthcare billing employee may each see a different part of that process. If the assessment or bill described care differently from what you saw and recorded, that gap is something our experts can examine with you.

Staffing records connect the care documented for a shift with the people working it. We examine those records with someone who knows how the facility actually worked, alongside the clinical notes and claims.

When the Care Record Serves the Revenue Target

In a separate case, SavaSeniorCare allegedly pressured facilities to reach the highest Medicare therapy categories without regard to residents’ clinical needs. The Justice Department’s settlement announcement described allegations of insufficient staffing and failures in pressure-ulcer, falls and medication protocols, along with unnecessary therapy and delayed discharges.

A whistleblower’s amended complaint described how the alleged incentives reached facility management:

That allegation makes the financial pressure concrete. The people directing care allegedly had their own compensation tied to Medicare billing and patient volume. Sava’s resolution required independent review of stays and paid claims as well as an independent care monitor. Those reviews addressed both what the company billed and what residents received, the same connection a wound-care insider may be able to explain.

You Know the Care Behind the Claim

If you saw wound-care records describe treatment that residents did not receive, speak to our whistleblower experts about what happened inside the facility. We work beside you to build the case around the clinical facts, the government claims and the decisions that connect them, and bring in nursing home fraud whistleblower lawyers who understand care-quality cases. We stay with you through the pursuit of a recovery.