Genesis Behavioral Services self-disclosed to OIG and settled for $100,000 for paying Qualified Behavioral Health Specialists to recruit other QBHSs who then referred clients to Genesis for Medicare and Medicaid-reimbursed mental health treatment.

Genesis Behavioral Services (Euclid, OH) — Anti-Kickback Violation / Referral Payments

Outcome: Self-disclosed to OIG and settled for $100,000 for paying Qualified Behavioral Health Specialists to recruit other QBHSs who referred clients to Genesis for Medicare and Medicaid-funded mental health outpatient treatment.

Genesis Behavioral Services, a behavioral health provider in Euclid, Ohio, violated the Anti-Kickback Statute by creating a referral payment scheme involving its Qualified Behavioral Health Specialists (QBHSs). The organization paid QBHSs financial incentives in return for recruiting other QBHSs who then referred their clients to Genesis for mental health outpatient treatment services.

The payments created a two-level incentive structure: existing staff were financially rewarded for recruiting new staff who would bring their client rosters to Genesis. Since the referred treatment services were reimbursed by Medicare and Medicaid, the referral payments tainted those claims as kickback-induced, violating the federal Anti-Kickback Statute and Civil Monetary Penalties Law.

Genesis Behavioral Services voluntarily self-disclosed the conduct to OIG, which resulted in a settlement of $100,000 recorded November 5, 2025.

Primary Source: Genesis Behavioral Services Agreed to Pay $100,000 for Allegedly Violating the Civil Monetary Penalties Law by Paying Improper Remuneration in Exchange for Referrals