When a healthcare provider submits claims to Medicare, they are making several implied representations: 1) the service was medicaly necessary; 2) the service was performed; and 3) the service was performed by someone with the proper credentials. If any of those implied representations are not accurate, and the provider has the requisite “knowledge” of the falsity, the claims violate the civil False Claims Act.
A hospital in Iowa learned this lesson the hard way. Marty Stempniak, writing for Radiology Business:
The U.S. Attorney’s Office first filed suit against University of Iowa Health Care in 2019, accusing the institution of perpetuating a “batch signing scheme.” Through it, the Iowa City hospital would allegedly bill for radiology services rendered by residents during 12- to 15-hour on-call shifts.
However, the physician supervision and approval required by Medicare never occurred, the office alleged in its complaint. …
Rather than complete the necessary review, the office alleged, physicians instead would engage in “rapid-fire signing of dozens of reports within a matter of a minute or so, solely in order to falsely bill the government for ‘interpretations’ that never took place,” the complaint alleged.