Springbok Health: High-Complexity E/M Claims for Lower-Level Counseling

In the Springbok Health fraud case, the clinic and its owner and CEO agreed to pay at least $125,000 and up to $335,494 to settle allegations of billing for expensive medical evaluation and management when, at most, they provided less expensive counseling. The government based the settlement on their ability to pay. For someone working inside a treatment clinic, the allegation reaches a familiar divide: the care a patient received and the service the government was asked to buy.

What Springbok Health Was Alleged to Bill

The government alleged that Springbok Health billed Medicare and Medicaid for high-complexity and prolonged medical evaluation and management services that were not rendered. The Justice Department’s April 18, 2022 announcement described a medical clinic with locations in Colorado Springs and Pueblo West, Colorado. The alleged billing ran from 2017 through 2019.

We see the absurdity in asking Medicare and Medicaid to pay for sophisticated medical work that the government says never happened. A counseling encounter does not become a high-complexity medical evaluation because the bill describes it that way.

The Department of Justice placed the case in the context of substance abuse treatment and Colorado’s opioid crisis. Its point was straightforward: public money spent on inflated claims takes resources from the health care programs paying for treatment. The purpose of a clinic makes accurate billing more consequential, not less.

Why the Service Behind the Code Matters

Outpatient behavioral health billing connects a professional service to the eligible practitioner, the work documented and the time involved. Medical assessment, medication management and psychotherapy describe different work within the same broader treatment business.

The Centers for Medicare & Medicaid Services’ March 2026 mental health coverage guide distinguishes professional services and practitioner qualifications from the requirements that apply to facilities and programs. Those distinctions help explain why an insider’s knowledge matters. Someone who knows which professional saw a patient and what happened during the encounter can supply information that the billed service description alone cannot.

Time also needs a service attached to it. In its January 2025 revision, First Coast’s Medicare psychotherapy coding guidance requires start and stop times or total psychotherapy time, excluding time spent on evaluation and management. It treats the therapeutic work and the medical work separately. That is a useful operational distinction for a clinic where both occur during a visit: the time spent on one service cannot simply stand in for the other.

The Clinic and Its Owner Both Agreed to Pay

Springbok’s civil resolution included both the company and its owner and CEO. The Justice Department attributed the alleged billing to both.

Inside a healthcare business, the treating professional and the billing organization can be different. A clinician knows the encounter. A billing employee sees how it becomes a request for payment, while leadership may know how the business directs that process. We connect those different views when assessing a suspected billing scheme.

The Justice Department’s Civil Division and federal prosecutors in Colorado worked on the resolution with the Department of Health and Human Services Office of Inspector General and the Colorado Attorney General’s Medicaid Fraud Control Unit.

A Parallel E/M Billing Allegation

The government’s complaint concerning Ultimate Treatment Center alleged that daily methadone dosing was billed as E/M even though the nurse took no patient history, performed no examination and made no medical decisions.

What a Clinic Insider Sees That a Bill Does Not

A clinic insider may know what happened during a visit and who decided how to bill it. The professional involved, the clinical work and the documented time give the claim its meaning. Our whistleblower experts work with insiders to connect those facts to particular government claims when assessing suspected evaluation-and-management upcoding.

A clinical note and a billing entry describe the same encounter from different sides of the business. We examine where those accounts diverge. An insider may know that the note describes work nobody performed, that the code misstates the service, or that management directed how claims were submitted.

This is where an employee’s account can carry more than a billing report alone. The report shows what the clinic charged. The person who saw the work or handled the billing can explain the decisions behind that charge. We build the case around that connection, with the treatment, documentation and payment rules for the encounters at issue.

How Much of a Settlement Does a Whistleblower Get?

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

Springbok’s settlement included a qui tam case brought by a whistleblower against the clinic and its owner and CEO. The Justice Department announced that the whistleblower would receive a share of the settlement.

You Know What Happened in the Treatment Room

If your clinic’s claims describe medical work you know patients did not receive, speak to one of our whistleblower experts about how those claims were billed. We build your case around the gap between treatment and payment, bring in healthcare fraud whistleblower lawyers who understand clinical billing, and stay beside you throughout the case.