Touchstone Strategies-Bulverde LLC; The Heights of Bulverde
Outcome
Touchstone Strategies-Bulverde LLC and The Heights of Bulverde in Texas paid $436,092 after employing an excluded individual whose services were billed to federal healthcare programs.
Details
The Heights of Bulverde (Texas) — Excluded Individual Employed, $436K Penalty (2024)
Outcome: Touchstone Strategies-Bulverde LLC and The Heights of Bulverde, senior care facility operators in Texas, paid $436,092.32 after self-disclosing that they employed an excluded individual whose services were billed to federal healthcare programs.
Touchstone Strategies-Bulverde LLC and The Heights of Bulverde operated a senior care community in Bulverde, Texas. They employed an individual who had been excluded from participation in any Federal health care program, and the excluded person's services were billed to Medicare and/or Medicaid. The $436,092.32 penalty — substantially higher than typical excluded-employee settlements — reflects either a prolonged period of the individual's employment and billing, or the provision of high-cost services during the excluded period.
The organizations self-disclosed the violation to the OIG on October 8, 2024. Assisted living and senior care facilities participating in federal healthcare programs must screen all employees, contractors, and independent contractors against the OIG LEIE at the time of hire and monthly thereafter.
Primary Source: OIG Enforcement Record
How Crucible Prevents This
Crucible's LEIE exclusion screening hooks and monthly monitoring controls would catch excluded staff before services are rendered. The $436,092 penalty significantly exceeds typical excluded-employee settlements, indicating either a long period of excluded employment or high-billing services. Automated monthly OIG LEIE cross-referencing is a non-negotiable compliance control for assisted living facilities.
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