Transcranial Doppler Testing in Eye Practices: The Diagnosis Missing From the Patient’s History

Whistleblower Justice Network

Transcranial Doppler testing in ophthalmology can become billing fraud when practices use false diagnoses to obtain Medicare and Medicaid payments for medically unnecessary cranial ultrasounds. The Justice Department’s eye-practice settlements describe that alleged path through third-party testing and referral arrangements. If you handled the orders, diagnosis entries or bills, you may recognize the central contradiction: a serious diagnosis used for payment that neither the patient’s medical history nor the test result supported.

What Happened Before the Patient Received the Transcranial Doppler Result?

The Justice Department alleged that eye practices and their testing provider identified patients as having a serious diagnosis before those patients received their transcranial Doppler results. The government’s account of Brandon Eye Associates shows how the process allegedly began: patients with common conditions, including diabetes, hypertension and glaucoma, received tests through a provider of turnkey mobile transcranial Doppler services.

According to the Brandon Eye announcement, the practice and testing provider identified patients as having a serious diagnosis, most commonly occlusion and stenosis of their cerebral arteries, that could qualify the test for reimbursement. The government alleged that nearly all the tested patients never had that arterial condition. It appeared in neither their medical histories nor their TCD results.

That is the specific medical necessity fraud allegation here: Medicare and Medicaid were billed for tests justified by a condition the patients allegedly did not have. We see a diagnosis serving the bill while the patient’s own history and result contradict it. For someone who entered the diagnosis or handled the result, the useful question is who supplied that clinical story and how it reached the claim.

Where the Diagnosis Met the Claim

The Brandon Eye allegations connect the diagnosis to a technical-component claim and a separate referral for the professional component. For each transcranial Doppler test ordered for a Medicare Part B patient, the government said Brandon Eye claimed the technical reimbursement, paid the testing provider based on the volume or value of tests ordered, and referred the patient to that provider’s preferred radiology group for the professional component.

The distinction between technical and professional imaging claims matters to the person following the paperwork. The technical component pays for producing the image, as the Robert Wood Johnson Foundation’s imaging explanation describes. The professional component covers interpretation and a written report, as the Medicare Claims Processing Manual’s imaging guidance explains.

The test order, the technical bill and the interpreting professional’s report therefore answer different questions about the same patient. Someone routing the study to radiology may know what clinical information accompanied it. Someone submitting the claim may know where the diagnosis came from. Putting those accounts together lets us examine how a reason for testing became a representation to Medicare.

The Payments Behind the Transcranial Doppler Referrals

The Florida announcements described practices paying a testing company according to the volume or value of tests ordered. The January 2026 announcement also alleged that the practices referred patients to the company’s preferred radiology group for interpretation. The arrangement connected the order, the vendor’s compensation and the destination of the professional work.

The New York allegations described an additional payment in the other direction. In its announcement concerning Fromer Eye Centers and Floral Park Ophthalmology, the Justice Department alleged that the testing company paid Floral Park to induce referrals of Medicare and Medicaid patients for transcranial Doppler tests.

These referral-payment allegations connect health care decisions to the vendor relationship. The government alleged violations of the Anti-Kickback Statute and the Stark Law governing physician financial relationships and referrals. A practice’s payment to a testing company and a testing company’s payment to a referring practice each deserve their own account: who authorized it, what it paid for and which orders it followed.

Why the Technical Component Makes Volume Matter

Imaging revenue can increase without a matching increase in the physician’s own working time. The Robert Wood Johnson Foundation’s 2008 research synthesis, Physician Self-Referral and Physician-Owned Specialty Facilities, explains the incentive:

However, it requires little extra time for a physician to receive a share of profits generated by facility fees paid to hospitals or ASCs, or from the technical fee component of imaging services.

Physician Self-Referral and Physician-Owned Specialty Facilities, Robert Wood Johnson Foundation, 2008

The report reviewed imaging studies that found physicians with a financial interest in referrals were much more likely to order imaging. In the eye-practice cases, the specific allegation was that a company received payments tied to testing volume or value while claims relied on diagnoses absent from patients’ histories and results. That gives an insider a concrete connection to explain between the clinical decision and the money earned from it.

The Eye-Practice Settlement Series

The settlements show the alleged testing arrangement reaching practices in Florida and New York. Gulfcoast Eye’s announcement identified the same testing provider involved in an earlier Florida settlement.

Brandon Eye Associates agreed to pay $1.3 million in the settlement announced November 12, 2024. The settlement resolved allegations involving medically unnecessary transcranial Doppler tests, false diagnoses and the third-party arrangement. The practice’s technical billing and its referrals for professional interpretation made both sides of the test visible.

Gulfcoast Eye Care agreed to pay $615,000 in the settlement announced May 20, 2025. Behind that settlement were allegations that the practice and a third-party provider performed transcranial Doppler tests on thousands of patients and billed Medicare and Medicaid hundreds of dollars per test. A whistleblower’s qui tam case led to the resolution.

On January 15, 2026, the Justice Department announced settlements totaling nearly $6 million with five Florida practices: Clay Eye Holdings, Retina Macula Specialist of Miami, Florida Eye Institute, Miami Eye and Kendall Eye Institute. Those settlements resolved allegations involving unnecessary transcranial Doppler tests, false diagnoses and the testing-company arrangement. The announcement said the whistleblower who brought the case would receive a $1.1 million reward.

The July 31, 2026 announcement added a $2.3 million settlement total involving Fromer Eye Centers, its former owner’s estate and Floral Park Ophthalmology in New York. It described allegedly unnecessary claims to Medicare and, for Fromer Eye, Medicaid. Alongside those billing allegations, the announcement separately described Floral Park’s alleged receipt of payments for referrals. The payer and the direction of the money matter when an insider explains which part of an arrangement they saw.

The Justice Department’s Civil Division and the U.S. Attorney’s Office for the Middle District of Florida handled these settlements, with assistance from HHS-OIG and the FBI. The announcements also said the settling practices agreed to cooperate with investigations of other participants in the alleged scheme.

What an Eye-Practice Insider Can Connect

An insider can connect the patient-selection process to the diagnosis, the test result, the component claims and the vendor payments. The person who knows how the practice worked can explain decisions that the final claim does not describe.

Someone handling orders may know how patients with common conditions reached the mobile-testing schedule and who supplied the indication. A staff member entering diagnoses may know whether an instruction came from the practice or the testing provider. Someone handling results can explain how the diagnosis used for billing compared with the history and the interpretation that returned from radiology.

The financial side supplies another view of those same tests. Vendor invoices and payment records can show how compensation tracked orders, while referral records identify the group receiving the professional work. These connections between clinical and billing records let us examine the arrangement with the person who understood it from inside. We want to know who chose the diagnosis, who directed the referral and who understood how the payment worked.

A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers. When you bring us a physician practice fraud concern, we work with you to build your strongest case from what you saw and what the government paid.

When You Know How the Diagnosis Reached the Bill

If you handled transcranial Doppler orders, diagnosis entries, interpretations or vendor payments, tell our whistleblower experts where the patient’s history and the billing story diverged. We build your case with you, bring in healthcare fraud whistleblower lawyers who understand medical necessity and testing arrangements, and remain your partners throughout the process. Speak to us about who chose the diagnosis and how it reached the bill.

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