Home Health Fraud After a Sale: Who Pays for the Old Claims?

A former owner can agree to fund a home health agency’s settlement over Medicare claims and referral payments. In the Traditions Health resolution, GBHHC Holding Corporation agreed to pay on behalf of the business it formerly owned. For an employee who saw the billing or administered the physician contracts, the ownership change is part of the story.

Home Health Ownership and the Company Behind the Claims

The name on the office door can sit above several different billing entities. An investment firm’s place in the ownership chain is another question we examine with you.

Private equity has bought home health agencies repeatedly. A 2025 study in JAMA Health Forum identified 749 agencies involved in private equity acquisitions during 2006 through 2024, including 55 involved in secondary buyouts. It explains why an employee’s account may cross more than one ownership change.

Traditions’ own structure shows why the operating names matter. Its agreement identifies home health subsidiaries billing Medicare in Kansas, Missouri, Oklahoma and Texas. In Oklahoma, the McAlester hub and several branch offices operated under the same National Provider Identifier.

We start with the agency that furnished the care and submitted the claims, then connect it to the owners and the people making the decisions during that period. That is how an ownership story becomes useful to a whistleblower case.

What Did Traditions Health Disclose?

Traditions disclosed questions about patient eligibility and physician payments after an audit request prompted an internal review. Its settlement agreement says the company discovered the care-related conduct while responding to a Unified Program Integrity Contractor’s audit request.

The company made its first disclosure to the Department of Health and Human Services’ Office of Inspector General on September 9, 2024. It described Medicare payments for patients who may have been ineligible because the supporting documentation was inadequate. The questions concerned the required patient encounter and the need for skilled nursing services, both central to the home health certification chain.

The government’s allegation was specific: Traditions Health Care of McAlester knowingly submitted Medicare claims for medically unnecessary home health services from January 1, 2021 through November 4, 2024. For a clinician, the connection is between the patient’s documented condition, the care ordered and what the agency billed.

Medical-Director Payments and Patient Referrals

The separate referral-payment allegations concerned physicians paid as medical directors. In a supplement to its disclosure, Traditions described arrangements in which physicians may have been paid for work they did not perform, services that were not reasonable and necessary, or services performed before the written agreement was fully signed. A later disclosure extended those concerns to additional Oklahoma and Texas operations.

The United States alleged that Traditions paid physician medical directors in exchange for referrals and then billed Medicare for the referred patients. It also alleged that the financial relationships violated the Stark Law’s restrictions on physician referrals. We see the absurdity in paying for medical oversight when, in the government’s account, the agency was buying referrals. Medicare got the bill.

The periods differ by agency and allegation, so the contract and service dates matter more than the year on a settlement headline. Traditions said it investigated the causes, terminated all home health medical-director contracts and provided additional staff training. We would want to understand what the internal review found, who received it and how the response changed the arrangements employees had been administering.

Can a Former Owner Pay the Settlement?

Yes. Under the Traditions settlement agreement, GBHHC Holding Corporation, its former owner, agreed to pay $34,000,000 on the company’s behalf, including $22,682,460 in civil restitution. The payment obligation belongs to the former holding company and does not establish an investment sponsor’s role in the alleged conduct or settlement.

Once paid, the settlement also resolves specified government money claims against past and present corporate parents and owners for the same alleged conduct. The ownership history matters at both ends: who controlled the business during the alleged conduct, and which companies the settlement covers afterward. An employee who knows who approved the physician contracts can help connect the corporate structure to decisions inside the agency.

What Evidence Is Needed to Prove Fraud?

The useful evidence connects what employees saw to the services, referrals and claims the company submitted. In a business that has been sold, it also connects those decisions to the company and management responsible at the time.

For clinical staff, we compare the patient’s encounter record and skilled-care needs with the plan of care, visits and Medicare claims. The OASIS assessment and its payment inputs belong in that comparison too. An assessment, a certification and a claim serve different purposes. Following the patient’s information through them can show where the account changed.

For someone in finance or physician contracting, the useful comparison is the medical-director agreement against the work performed, compensation, referrals and resulting claims. The Traditions disclosures make the timing of the signed agreement especially relevant. A person who administered those arrangements may know what the physician was expected to do and what anyone checked before authorizing payment.

The audit response supplies another connection. We examine the request, the internal findings and the decisions that followed, alongside the ownership dates and billing entities. These are questions we work through with you, drawing on your knowledge of how the agency actually operated.

Other Home Health Settlements After a Sale

Altimate Care and the Earlier Owners’ Decisions

Altimate Care agreed to settle improper-billing allegations in May 2020. A former employee’s complaint alleged unnecessary nursing visits, patients who were not homebound and manipulated records used to justify claims to federal health care programs, including Medicare and Ohio Medicaid. It alleged that the former owners knew of and approved the activities. The Justice Department said the company was sold in 2018 and the new owners worked quickly to resolve the complaint.

Amedisys Bought After the Disclosure

Evolution Health’s settlement agreement places the disclosure before the acquisition. Evolution owned Guardian Health Care, Gem City Home Care and Care Connection of Cincinnati. The companies disclosed their conduct on March 14, 2022. Amedisys acquired them on April 1, 2022.

The government alleged that the agencies supplied lease payments, wellness services, sports tickets, meals and other benefits in exchange for Medicare referrals. The resolution announced in July 2024 followed that acquisition. The agreement identifies Amedisys’s role and separately assigns the settlement payment to the acquired companies.

Recovery Home Care and a Separate Former-Owner Resolution

Recovery Home Care and its purchaser, National Home Care Holdings, agreed to a corporate settlement announced in March 2015. The government alleged that physician chart-review payments exceeded the work performed and bought patient referrals. The purchaser had acquired the business after the conduct addressed in that settlement.

The former owner’s separate resolution followed in March 2016. It addressed allegations that the former owner caused the companies to pay the kickbacks, and the announced agreement required bankruptcy-court approval. A former employee had brought the whistleblower case, which the government joined in part.

We see a recurring question in these cases: who made the decision that sent the claim or bought the referral? An employee’s knowledge of that decision can connect the clinical and financial records across an ownership change. A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers.

You Know What Happened Before the Sale

If you handled the patient records, director contracts or audit response across an ownership change, speak with our whistleblower experts about what happened inside the agency. We connect your account to the decisions and Medicare claims, build your strongest healthcare fraud whistleblower case with you and bring in home health fraud whistleblower lawyers who understand physician payments and changes in ownership. You bring the knowledge of the business, and we stay beside you as your partners through the case.