Plano Doctor, Heal 360 Clinics Agree to Pay $20 Million Over Alleged COVID-19 Testing Fraud

DALLAS, Texas - A Plano physician and two medical clinic companies he owns have agreed to pay $20 million to resolve federal allegations that they billed a government COVID-19 relief program for hundreds of thousands of medical office visits that never occurred.

Dr. Mohammed Amer Mohiuddin, owner of Heal 360 Urgent Care PLLC and Heal 360 Primary Care PLLC, reached the settlement with the U.S. Department of Justice following an investigation into billing practices at dozens of COVID-19 testing locations across Texas.

Federal prosecutors alleged that between Jan. 1, 2021, and March 23, 2022, Heal 360 and Mohiuddin knowingly submitted false claims to the Health Resources and Services Administration's COVID-19 Uninsured Program.

The federal program reimbursed healthcare providers for COVID-19 testing, treatment and vaccinations provided to uninsured patients during the pandemic.

According to the Justice Department, Heal 360 operated dozens of COVID-19 testing locations, most of which offered drive-through or walk-up services.

Patients typically registered online or at the testing site, remained in their vehicles and received nasal swabs from clinic employees.

Prosecutors said those encounters involved specimen collection rather than comprehensive medical examinations or office visits.

However, investigators alleged that Heal 360 billed the federal government using higher-level evaluation and management codes, which are normally reserved for more extensive medical services.

Those codes carried substantially higher reimbursement rates than the codes authorized for collecting COVID-19 testing specimens.

Federal Investigators Allege Clinics Created Fictitious Medical Records

The Justice Department alleged that Heal 360 and Mohiuddin created template-generated medical records to make it appear that patients had received more extensive medical care than was actually provided.

The records contained sections for medical histories and examinations, despite patients receiving only COVID-19 testing services, according to federal prosecutors.

Investigators said remote medical scribes working overseas generated the records using information collected at the testing sites.

Although Mohiuddin did not personally visit or treat patients at those locations, prosecutors alleged that he was identified as the rendering physician on most of the claims.

Federal authorities said Heal 360 submitted hundreds of thousands of claims for higher-level evaluation and management services, resulting in payments the government contends the companies were not entitled to receive.

The allegations involved billing codes typically used for more complex office visits, including CPT codes 99203, 99204, 99213 and 99214.

For COVID-19 specimen collection performed by clinical staff under the applicable federal billing rules, providers were instead required to use CPT code 99211.

Whistleblower Lawsuits Lead to $20 Million Settlement

The settlement resolves two civil lawsuits filed under the whistleblower provisions of the federal False Claims Act.

Those provisions allow private individuals to file lawsuits on behalf of the federal government when they believe public funds have been obtained through fraudulent claims.

The whistleblowers involved in the Heal 360 cases will receive a combined $3.4 million from the settlement proceeds.

The government also reached an agreement with Mohiuddin involving a related asset forfeiture case concerning real estate he purchased.

Proceeds from the sale of those properties will be credited toward the $20 million settlement.

The civil resolution addresses the government's allegations and does not, by itself, constitute a criminal conviction or a judicial finding that the defendants committed fraud.

Federal Prosecutors Warn Against Healthcare Billing Fraud

U.S. Attorney Ryan Raybould for the Northern District of Texas said the settlement demonstrates the federal government's efforts to recover taxpayer funds allegedly obtained through improper healthcare billing.

“Through the combined efforts of civil fraud and asset forfeiture prosecutors from my office, civil fraud prosecutors in the Eastern District of Texas and at Main Justice, and outstanding investigative work by our agency partners at the HHS Office of Inspector General, we were able to secure this substantial recovery for the benefit of the American taxpayer,” Raybould said.

Assistant Attorney General Brett A. Shumate of the Justice Department's Civil Division said federal authorities remain focused on healthcare providers accused of billing for services they did not deliver.

“The Department is committed to rooting out fraud by healthcare providers who bill for services they did not provide,” Shumate said.

U.S. Attorney Jay R. Combs for the Eastern District of Texas also emphasized the government's efforts to recover funds obtained through alleged misrepresentations.

The investigation involved the Justice Department's Civil Division, the U.S. Attorney's Offices for the Northern and Eastern Districts of Texas, and the U.S. Department of Health and Human Services Office of Inspector General.

The two whistleblower lawsuits were filed in federal courts in Dallas and the Eastern District of Texas.