CHC Holdings, LLC d/b/a Carter Healthcare
Outcome
Carter Healthcare and two former corporate officers (Stanley and Brad Carter) settled for $22,948,004 for paying physicians under guise of medical directorships to induce home health patient referrals to Medicare and TRICARE.
Details
Carter Healthcare (Oklahoma City) — $22.9M Physician Medical Directorship Kickbacks
Outcome: Carter Healthcare and former officers Stanley Carter and Brad Carter settled for $22,948,004 for disguising illegal referral kickbacks as physician medical directorship payments, generating fraudulent Medicare and TRICARE claims.
CHC Holdings, LLC, doing business as Carter Healthcare, a home health company headquartered in Oklahoma City with operations in Texas and Oklahoma, operated a scheme to generate patient referrals by paying physicians under the guise of medical director arrangements. The payments were not legitimate compensation for medical director services but rather disguised kickbacks designed to induce physicians to refer their patients to Carter Healthcare for home health services.
The scheme resulted in false claims being submitted to Medicare and TRICARE — the federal healthcare program for military personnel and their families — for home health services generated through the illegal referral payments. Two former corporate officers, Stanley Carter and Brad Carter, were named alongside the company entity in the settlement.
The $22,948,004 settlement was announced October 18, 2022, by the U.S. Attorney's Office for the Western District of Oklahoma. A Corporate Integrity Agreement was also imposed as a condition of resolution.
How Crucible Prevents This
Crucible's medical directorship compensation audit hooks would flag arrangements where physician payment correlates with referral volume; a compliance gate requiring independent FMV analysis of all medical director agreements and Stark Law safe harbor documentation would catch sham directorship kickback arrangements before they generate $22M in fraudulent claims.
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