Great Lakes Home Healthcare Specialists: Therapy Units, an Absent Employee, and Altered Dates

The $450,000 Great Lakes Home Healthcare Specialists settlement resolved False Claims Act allegations of false Medicare billing against the Traverse City agency, its sister company Great Lakes Therapy Housecalls and their owner. The government alleged extra therapy units for work never performed, a supervisor’s credentials used during maternity leave, social work by an unqualified employee and altered physician-signature dates. For a therapist, scheduler or biller, those allegations reach familiar records: the visit note, the staffing file and the claim that left the office.

What the Great Lakes Settlement Resolved

The Justice Department announced the company and owner settlement on November 3, 2021, following a civil case brought by the United States in the Western District of Michigan. The U.S. Attorney’s Office for that district, the Department of Health and Human Services Office of Inspector General and the FBI worked together on the resolutions.

The businesses and owner’s agreement followed a separate civil settlement with the former office manager at Therapy Housecalls in September 2021. He agreed to pay $75,071 over his role in the additional physical and occupational therapy unit billing.

The government’s complaint describes businesses with different billing arrangements. Great Lakes Therapy Housecalls provided physical and occupational therapy, including treatment in patients’ homes billed under Medicare Part B. Great Lakes Home Healthcare Specialists provided home health care to homebound beneficiaries under Part A. Their common owner was a licensed physical therapist.

That distinction follows the allegations. The additional therapy units and absent supervisor concerned Therapy Housecalls. The unqualified social worker and altered certifications concerned Home Healthcare Specialists. The same owner sat above different representations about the care Medicare was buying.

The Extra Therapy Unit That Reached Medicare

The government alleged that Therapy Housecalls added a fifteen-minute therapeutic-activities unit to claims even though nobody provided that additional therapy. The extra unit carried CPT code 97530, a code for one-on-one therapeutic activities. According to the complaint, the owner directed an employee to add it to physical and occupational therapy claims.

The ordinary billing workflow made the alleged addition traceable. Therapists recorded the services and units on a progress note after a home visit. They also completed a daily billing chart identifying the patient, service code and units. The claim sent to Medicare was supposed to reflect those records.

In one example, the complaint describes a physical therapist assistant’s progress note and daily billing chart showing four units: therapeutic activities, therapeutic exercises and gait training. The submitted claim showed five. The government alleged that the added unit typically generated approximately $23 in extra Medicare payment on each affected claim, and that the practice appeared in hundreds of claims.

The visit was over. In the government’s account, the bill kept growing.

We look at where the unit count changed and who directed the change. Here, the complaint put the therapist’s contemporaneous account beside the billing record and the paid claim.

Home Health Physical Therapist Name Used During Maternity Leave

The government alleged that Therapy Housecalls used a physical therapist’s name and Medicare credentials to bill for assistants’ work while she was on maternity leave and providing no supervision. The complaint identifies the period as April 25 through July 1, 2013, and alleges dozens of claims.

Many of the company’s home visits were performed by physical therapist assistants. The complaint explains that Medicare coverage depended on appropriate supervision by a physical therapist. This employee normally supervised the assistants, and the company billed under her credentials for their work.

According to the complaint, the billing continued under her name during her absence. It also alleged that the company used a signature stamp to put her signature on the underlying therapy records, making those records appear to support supervision she had not provided.

The alleged falsehood reached both the claim and the paperwork behind it. An employee familiar with the supervisor’s leave could recognize something the signature alone concealed. We would connect that knowledge to the assistants’ visits, the credentials used for billing and the records bearing the stamped signature.

An Unqualified Medical Social Worker

The government alleged that Home Healthcare Specialists hired a medical social worker who lacked the required degree and Michigan license, then billed Medicare for episodes that included her services. The complaint places that work from around September 2016 through around February 2018.

Medical social services in home health can address the social and emotional factors affecting illness, treatment and adjustment to care. The complaint described qualifications for the work and alleged that the agency’s own personnel file showed the problem at hiring:

The complaint also alleged that the same file contained the agency’s qualification requirements. That put the worker’s disclosure beside the standard the agency said the job required.

The payment connection was an episode of care. Under the payment system described in the complaint for the period at issue, Medicare paid the home health agency for a sixty-day episode covering multiple services. In one alleged example, Medicare paid $5,086 for an episode covering a social-work evaluation, visit and discharge alongside other home health services.

The same connection between qualifications and claims appears in home health aide qualification cases. In the case involving Nursing Personnel Home Care, the government alleged false training credentials or missing training behind Medicaid payments. The profession and payer differed, but the personnel file again mattered to what the agency billed.

Physician Dates Changed After the Fact

The government alleged that Home Healthcare Specialists directed an employee to change dates on physician certifications and recertifications to avoid Medicare denials for untimely signatures. According to the complaint, the agency faxed forms to physicians, some came back signed later than the agency wanted, and management directed the alterations.

The home health certification chain connects the patient’s eligibility and plan of care to payment. The complaint explains that the physician had to sign and date the certification, with continuing care requiring recertification. Its account of what happened to those dates is unusually concrete:

The complaint further alleged that the employee complained to coworkers about the time the alterations took and showed them a stack of records awaiting the same treatment. We see the absurdity in that account: staff time spent making a physician’s approval look earlier while removing the document that showed when it actually came.

A 2023 analysis in Georgetown Environmental Law Review draws on Medicare certification cases to explain why timing matters to payment. The paper points to certification as a payment condition and to government guidance emphasizing timely certification as central to what Medicare is buying.

The Abington Memorial Hospital settlement concerned a similar alleged substitution. The government resolved allegations that home-care claims carried copied physician signatures instead of genuine authorization. In both accounts, the apparent physician approval concealed a decision made inside the organization submitting the claim.

What Evidence Is Needed to Prove Fraud?

The Great Lakes complaint compares progress notes with billed units, leave dates with claimed supervision, hiring disclosures with job requirements, and original certifications with replacements. Our whistleblower experts connect those records to what you saw inside the agency. In home health, an OASIS assessment helps determine payment, so we trace changes from the assessment and visit record through to the claim.

An insider may know who ordered the extra unit, who handled the signature stamp or why an original disappeared. A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers.

You Know Which Record Changed

If the treatment you recorded became a different Medicare claim, or you saw a physician’s date replaced, talk with our whistleblower experts about what happened inside the office. We build your case around the care, the billing and the decisions you know, bring in Medicare fraud whistleblower lawyers who understand therapy and home health claims, and stay beside you throughout the case.