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In the Mindpath Care Centers fraud case, the company and former officers paid $1.9 million to the United States to resolve allegations of false Medicare billing for psychotherapy and medication management. The government alleged that the practice billed without documenting separate psychotherapy and failed to adequately correct problems employees repeatedly raised.
The U.S. Attorney’s Office for the Eastern District of North Carolina announced the settlement on December 2, 2025. It described Mindpath Care Centers, North Carolina, PLLC as North Carolina’s largest behavioral health practice, with offices statewide. The alleged billing period ran from 2018 through 2020.
The case arose from whistleblower allegations. The United States then filed a complaint alleging systematic billing for psychotherapy without the required documentation of the treatment and its separate time. The U.S. Attorney’s Office and the Department of Health and Human Services Office of Inspector General handled the matter together.
The government’s allegation concerned Medicare claims for psychotherapy alongside medication management without documentation showing separate and distinct psychotherapy. According to the Justice Department’s account of its complaint, the defendants billed this way to maximize profits. We expect the extra charge to stand on the work behind it. In the government’s account, that support was missing.
Outpatient psychiatry puts diagnosis, medication management and therapy within the same practice, but billing still depends on the professional service delivered, the practitioner and the documented work. A combined visit can involve both medical evaluation and psychotherapy. The payment question follows each service within that visit.
Medicare contractor guidance makes that separation concrete. In its coding article effective January 1, 2025, First Coast Service Options describes psychotherapy add-on codes used with a medical evaluation and management service. Code 90833 corresponds to 16 through 37 minutes of psychotherapy, and 90836 to 38 through 52 minutes. The article requires documentation of psychotherapy time and excludes the time devoted to evaluation and management from that total.
The same guidance recognizes that psychotherapy may occur in separate portions of a combined visit. The documentation still has to identify the psychotherapy and its time. For an employee looking at a schedule and a clinical note, the appointment’s overall length and the time spent providing psychotherapy answer different questions.
The WPS Medicare contractor article effective January 1, 2026 describes both services as significant and separately identifiable. It selects the medical evaluation and management service by medical decision-making when psychotherapy add-ons are used.
The government alleged that Mindpath failed to adequately correct problems employees raised repeatedly and brushed aside their concerns about billing fraud while focusing primarily on generating income. Those allegations connect the claims to decisions inside the business.
A clinician may know what happened during a visit. A billing employee may know what service the claim ultimately represented. Comparing those accounts can expose the distance between the work performed and the work charged to Medicare. When concerns have reached management, we also want to understand what the concern identified and what happened to the billing afterward.
By the government’s account, the warnings kept coming. We would examine the connection between the concern, the people who received it and the affected billing.
An insider may know the disputed service description, the question about the note supporting it, or the decision about whether the claim should change. Our work is to connect that account to the service Medicare paid for. The clinical detail and the business decision belong in the same conversation.
In a psychotherapy billing case, the useful evidence connects what the claim represented with the care actually delivered and what the practice knew about the difference. We examine the claim, service date, clinician, schedule, documented treatment and psychotherapy time together. The employee’s account explains how those pieces fit.
The First Coast guidance shows why the treatment note matters. It calls for the signature of the professional responsible for and providing the care, requires the billed code to describe the service performed, and requires time documentation where time determines payment. Those details give a reviewer something specific to compare with the claim.
For a combined visit, the comparison has to reach inside the appointment. We want to understand which part of the recorded care supports the psychotherapy charge and how the claim arrived at that description. Your knowledge of the clinical work or the billing process can explain a discrepancy that the claim alone leaves hidden.
The payment resolved the False Claims Act allegations. We see an absurd bargain: the practice and former officers paid to end allegations that they ignored employee warnings, yet admitted nothing. Taxpayers funded the claims. A settlement should not be where accountability stops.
Billing for an additional service that the patient did not receive is one example. A whistleblower’s complaint against Turning Point Care Center alleged that the patient received psychotherapy, while the claim added a medical evaluation service the patient did not receive.
In another example, Relator recalls an incident where a patient received a 45 minute individual psychotherapy session (90834), but TPCC submitted a false claim billing Medicare for a 45 minute individual psychotherapy session with evaluation and maintenance (90836 + E&M code).
The common point is the second service on the bill. The government’s allegation against Mindpath concerned missing documentation of separate psychotherapy, which does not itself establish that psychotherapy never occurred. Turning Point’s whistleblower alleged an additional service that was not provided. In each account, the claimed combination requires a closer look at the individual services, rather than treating the presence of a patient as the whole answer.
For someone working in outpatient mental health care, a code added to a real encounter can be the part that deserves scrutiny.
A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers. If you know how a healthcare practice turned undocumented services into claims, our whistleblower experts can help you explore a case built on that knowledge.
If you saw psychotherapy added to medication visits or heard employee concerns repeatedly dismissed, talk with our whistleblower experts about the claims and decisions you know. We work alongside you to build the case, select Medicare fraud whistleblower lawyers with psychiatric billing experience, and stay with you through the pursuit of a recovery.