Today’s Youth: Unlicensed Clinicians on Licensed-Provider Claims

In the Today’s Youth fraud case, the company and its owners agreed to pay $273,000 to resolve allegations that they billed Connecticut Medicaid for licensed clinicians’ services when unlicensed workers provided the care. The company had a state contract to treat Medicaid patients. The government alleged that its claims concealed a difference that determined whether Medicaid would pay: the qualifications of the person who actually delivered the service.

Today’s Youth LLC provided in-home family therapy and counseling in the greater Hartford area. The U.S. Attorney’s Office for the District of Connecticut announced the civil settlement on April 6, 2021. It covered alleged improper billing between January 1, 2014 and September 1, 2019.

The Office of Inspector General for the U.S. Department of Health and Human Services investigated the case. The U.S. Attorney’s Office and the Connecticut Office of the Attorney General handled it.

What the Claims Allegedly Misrepresented

The government alleged that Today’s Youth and its owners routinely submitted behavioral health claims as though a licensed clinician had performed the services. According to the announcement, unlicensed providers had actually done the work, and Medicaid paid for services the federal and state governments would not have paid for had they known that.

Today’s Youth was enrolled in the Connecticut Medical Assistance Program, which includes the state’s Medicaid program, as a Behavioral Health Clinician Group. The Connecticut Department of Social Services contracted with the company to provide behavioral health services to Medicaid beneficiaries. That enrollment put the organization in the payment system. The alleged problem was what it represented about the people delivering the care.

Did Supervision Satisfy Connecticut’s Billing Rule?

Supervision did not satisfy the independent-practice billing rule described in the Today’s Youth settlement announcement. The Justice Department explained that Connecticut’s Department of Social Services did not allow licensed behavioral health clinicians in independent practice to submit claims for services provided by unlicensed people, even when those people were working toward licensure and a licensed professional supervised them.

The announcement identified the department’s provider manual for licensed behavioral health clinicians in independent practice as the source of the restriction. The government alleged that Today’s Youth submitted the claims despite that guidance.

The government’s allegation put taxpayers on the hook for care presented as a licensed clinician’s work when an unlicensed worker had delivered it. We see the absurdity: the provider’s qualifications mattered enough to secure payment, but allegedly disappeared when it came to delivering the care.

The Organization, the Clinician and the Claim

Today’s Youth had a state contract to provide care. The government’s allegation turned on the qualifications of the person who delivered it.

For a biller, the submitted claim may be the familiar part. For a treating worker, it may be the session and the supervision arrangement. For someone responsible for credentials, it may be the worker’s licensure status. We connect those views to the particular service and payment rule. An insider’s knowledge of who did the work can explain a discrepancy that the organization’s enrollment record alone cannot.

When the Billing System Selects Someone Else

A separate whistleblower complaint alleged that Connections Community Support Programs’ management instructed workers to bill under a licensed clinician’s name even when that clinician neither provided nor supervised the services.

The Connecticut Parallel Went Beyond Credentials

In Connecticut, the government alleged that Behavioral Management billed Medicaid for individual psychotherapy by licensed providers when unlicensed workers delivered group services.

The Civil Settlement and the Whistleblower Opportunity

A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers. For someone who sees healthcare claims presented under qualifications the treating workers do not hold, the value of that knowledge lies in connecting the actual care to the claim and the decisions behind it.

You Know Who Delivered the Care

If the clinician on the claim differs from the worker who treated the patient, talk with our whistleblower experts about what you saw. We build the case with you and bring in behavioral health fraud whistleblower lawyers who understand Medicaid billing and provider qualifications. From the first call, we stay on your side to build your strongest health care fraud whistleblower case.