This is a common tale. It seems like most of my time is spent explaining to clients why you cannot pay marketers a percentage of the revenue derived from patients they refer to them. Press Release from Texas Attorney General:
Griffin obtained patients by offering and paying kickbacks to marketers as well as disguising illegal payments as marketing services and outsourced business services. Griffin then submitted false claims to both Medicaid and Medicare for orthopedic equipment that was never provided, not medically necessary, and not authorized by a physician.