Vanguard and Fleur de Lis: A Vitamin Injection by Any Other Name

The Vanguard Clinic Sanexas complaint alleges that a chiropractic clinic and a device distributorship promoted and billed Medicare for noncovered electrical stimulation treatments and vitamin injections. The government says the people behind the program supplied billing instructions, continued billing after acknowledging the coverage problem, and certified injections as medically necessary without knowing what was in them. The alleged scheme diverted Medicare money from patient care to treatments the program did not cover.

The Justice Department announced the False Claims Act complaint on March 16, 2026. It concerns The Vanguard Clinic LLC, Fleur de Lis, LLC and the chiropractor and emergency room physician behind them, with allegations reaching from a St. Louis clinic to nationwide promotion and distribution.

The Treatment Came With Billing Instructions

Vanguard was the integrated chiropractic clinic. Fleur de Lis was the Sanexas device distributorship. According to the government’s announcement, the chiropractor helped develop the treatment-and-billing scheme and promoted it nationwide. The emergency room physician served as Vanguard’s medical director, held that role at two other Sanexas clinics, and distributed the devices nationally.

Beginning in late 2018, the chiropractor allegedly promoted Sanexas treatments and accompanying vitamin injections as reimbursable by Medicare and supplied coding instructions. The alleged sales proposition therefore reached beyond buying a machine. It included how a clinic would get paid for using it.

The RST-Sanexas neoGEN-series device uses a large central unit with electrical leads temporarily attached to the area being treated. In its complaint against Vanguard, the government follows the treatment into the injection description, the patient-contact codes, the diagnostic testing and the resulting Medicare bills.

A More Billable Name for the Injection

The government’s complaint quotes a defendant discussing how to describe the injections:

The proposed improvement was to the name. The message’s stated test was which description would get paid.

The allegation about medical necessity is just as concrete. The government says Vanguard’s medical director falsely certified that the vitamin injections were necessary despite not knowing their ingredients. The complaint also quotes the chiropractor describing a vitamin blend mixed in a single bag for use across multiple patients. That puts the clinical sign-off beside the billing language: what the injection was called, what it contained, and what the physician certified about it.

Patient-Contact Codes Without the Patient Contact

The complaint alleges that the providers billed codes requiring direct, one-on-one patient contact while providing no such contact during Sanexas treatments. It identifies CPT codes 97032, 97110 and 97112, and says constant attendance was unnecessary once the Sanexas protocol was running.

That is a discrepancy a treatment-room employee could recognize. The claim described attended care. The government’s allegation describes a running machine.

Testing That Did Not Decide the Treatment

The government also alleges that epidermal nerve fiber density testing lacked clinical value because Vanguard patients received Sanexas treatment regardless of the results. Its account of the sequence is blunt:

The test was supposed to inform care, yet the complaint describes a treatment decision already made. For an insider, the appointment record, treatment start and arrival of the biopsy result tell that story together.

Medicare Billing Continued After the Warning

According to the complaint, the chiropractor told Vanguard employees in June 2020 that Medicare would no longer pay for patients’ neuropathy treatments and that patients would need to pay themselves. The government alleges that the providers nevertheless continued billing Medicare for Sanexas treatments and vitamin injections until May 2021.

The March 2026 announcement says the defendants acknowledged in their own federal complaint that Medicare did not cover their billing, yet the chiropractor continued to bill it.

The alleged contrast is between the instruction inside the clinic and the claims leaving it. A staff message saying Medicare would no longer pay means something different when the billing records show that the clinic kept asking Medicare for money.

How Does Reimbursement Work for Medical Devices?

For Sanexas, the Justice Department’s manufacturer settlement announcement describes FDA clearance for electrical nerve stimulation in limited circumstances. It also explains the coverage exclusion for electrical nerve stimulation furnished in physicians’ offices or outpatient clinics, and the restrictions on vitamin injections used for a nerve-block function.

That is why the treatment setting and injection purpose matter in this case. The government’s allegation concerns a program of outpatient stimulation and accompanying injections promoted as payable by Medicare. The product’s clearance and the availability of procedure codes did not supply that coverage.

The clinic’s bill also carried a description of care. A code requiring one-on-one attendance represented something about the treatment session itself. The alleged mismatch between that description and the work performed gives a billing or clinical employee a much more specific issue to recognize than a general promise that a device is reimbursable.

The Sanexas Pattern Across Other Clinics

Other Sanexas cases describe the connection between the manufacturer’s promotion and provider billing. In December 2025, RST-Sanexas and its owners agreed to a $1.5 million settlement, based on their ability to pay, over allegations involving noncovered services and kickbacks. The government alleged that the manufacturer paid commissions tied to distributors’ sales and offered volume-based discounts to provider-owned distributorships. It also alleged that the company received laboratory commissions for referring providers for nerve testing.

At the clinic level, the Active Integrated Medical Centers and Nova Integrated Health settlements covered nerve testing. Active Integrated allegedly offered Sanexas treatment regardless of the results of its TM Flow screening tests.

What Evidence Is Needed to Prove Fraud?

In a case about treatment promotion and Medicare billing, the evidence connects what the clinic was told, what it delivered, what it billed and what the decision-makers knew. The government’s complaint against Vanguard makes each connection tangible: reimbursement instructions, an injection-description message, patient-contact codes, biopsy timing and continued billing after a coverage warning.

The 2020 Journal of Forensic and Investigative Accounting paper A Forensic Accountant’s Guide to the Most Potent Federal Laws Used Against Healthcare Fraud describes reimbursement requests that misstate the services actually delivered. Here, the alleged gap is between what the claim said happened in the room and what did.

A billing employee may know who supplied the codes and whether they changed after a warning. A clinical employee may know whether anyone provided the contact those codes described. Someone involved in sales or distribution may know how the payment promise reached other clinics. We work with insiders to connect those accounts to the instructions, treatment records and claims that give them substance.

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

You Saw How the Treatment Became a Bill

If you know who supplied the Sanexas billing instructions or why claims continued after a coverage warning, talk with our whistleblower experts. We build the case with you and bring in medical-device fraud whistleblower lawyers who understand the connection between promotion, clinical records and Medicare claims. We stay alongside you from that first account through the pursuit of a recovery.