Great Circle: Billing for Supervision Foster Youth Did Not Receive

In the Great Circle fraud case, the Missouri nonprofit agreed to a $1,866,000 civil False Claims Act settlement over claims for enhanced residential supervision. Under a separate criminal non-prosecution agreement, Great Circle admitted falsely claiming services for six foster-youth residents during 2019 and 2020. The claims represented more staff and enhanced services above the facility’s licensed Level IV care. For someone who worked the shifts or saw the bills, the gap between the supervision claimed and the staff actually there is the heart of the case.

The Justice Department announced the agreements on February 24, 2023. Great Circle, based in Webster Groves, provided behavioral health services to children with special needs in the custody of the Missouri Department of Social Services, Children’s Division.

What Enhanced Residential Supervision Meant

Great Circle’s enhanced-supervision claims represented services above Level IV, including increased staff-to-resident ratios. In its account of the non-prosecution agreement, the Justice Department said the company falsely claimed those services on multiple occasions.

Level IV itself meant intensive residential treatment. The release described a highly structured, secure environment designed to prevent children from running away, address rage and physical aggression, and reduce the risk of residents injuring themselves or others. Extra supervision was being claimed on top of that already intensive setting.

A resident’s presence in the building does not show who supervised that child, how much supervision the child received, or whether the service described in the claim happened. Those are questions about the work on the floor, tied to a particular resident and the care billed for that resident.

We see the absurdity in the admission: a provider entrusted with children who needed intensive supervision billed the state for an extra level of it that it had not supplied. More supervision on paper.

A different youth-treatment setting offers a useful perspective on the promise of care. The 2023 Sharing Sociology essay Therapy or Fraud? examines wilderness therapy, describing marketing that promises licensed professionals, assessment and treatment planning alongside accounts of undertrained staff and limited psychiatric involvement. The connection here is the gap between a program’s description and the people actually delivering treatment, a gap that staff and families can see from inside the service.

Why Continued Care Mattered

Officials said the agreements held Great Circle accountable while preserving access to residential treatment for children in Missouri’s foster care program. Great Circle’s cooperation also figured in the government’s decision.

At the time of the announcement, Great Circle had locations throughout Missouri and in Kansas. KVC Missouri had announced plans to take over Great Circle on April 1, 2023.

What Agency Investigates Healthcare Fraud?

The Department of Health and Human Services Office of Inspector General and the FBI investigate health care fraud. State Medicaid Fraud Control Units investigate Medicaid provider fraud and patient abuse or neglect.

In Great Circle’s case, the Justice Department identified a coordinated effort involving those federal agencies, the U.S. Attorney’s Office for the Eastern District of Missouri and the Missouri Department of Social Services. The Missouri attorney general also credited the office’s Medicaid Fraud Control Unit.

Local police had a reason to be involved. The Webster Groves Police Department said the investigation concerned allegations of abuse of child health care recipients, failure to report abuse and Medicaid fraud. The Justice Department also named the Phelps County Sheriff’s Department among the agencies involved.

When Staffing Decisions Become Billing Evidence

Staffing and supervision also appear in other behavioral health false-claims cases. In its announcement of Acadia Healthcare’s civil settlement, the Justice Department described allegations that specified facilities submitted false claims arising from inadequate staffing, training and supervision, along with failures to provide active treatment and required therapy.

The whistleblower’s complaint in that separate case described a specific management response to a staffing requirement:

That allegation puts a decision inside the facility beside the staffing promise. It is the kind of detail an employee may recognize: who was supposed to be supervising, what management proposed instead, and how the claimed care compared with those instructions.

A different comparison appears in Eagleville Hospital’s detoxification settlement. There, a whistleblower alleged that the hospital admitted certain patients for higher-reimbursing hospital-level detoxification rather than residential treatment, without meeting the medical-necessity requirements for the higher level. Eagleville agreed to settle those allegations. The common question is what level of care the government was asked to pay for and what supported that claim. Great Circle’s case makes the staffing representation itself central to that question.

What Evidence Is Needed to Prove Fraud?

For an enhanced-supervision claim, the useful evidence connects the resident, the service represented to the payer, the staff who actually delivered it and the bill. We examine those connections with the person who knows the operation.

We compare staffing and resident-specific service records with the authorization and claim to understand what care was approved, what happened on the shift and what the provider said it delivered. An approval for enhanced care and evidence that enhanced care occurred answer different questions.

The same comparison explains why a staffing concern can become a payment concern. If a claim represents extra supervision, the relevant staffing evidence concerns the residents and service dates behind that representation. A general staffing total loses the connection between the particular child, the supervision claimed and the people present to provide it.

An employee responsible for scheduling may understand an assignment that a billing employee sees only as a service description. Someone providing care may recognize that the description does not match the shift. Our work is to connect that operational knowledge to the payment representation and the decisions behind it.

For a worker who sees a mismatch between promised supervision and an actual shift, the organization’s response matters: who receives the concern, what they understand about the staffing, and what happens to the billing afterward. Those connections are part of the case we examine with an insider.

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

You Know Who Was on the Shift

If you know how residential supervision on a bill differed from the care children received, talk with our whistleblower experts about the staffing and claims you saw. We build the case with you and bring in behavioral health fraud whistleblower lawyers who understand residential staffing and government payment. You bring the view from inside the facility; we bring the expertise and partnership to pursue the case alongside you.