Windsor Laurelwood Center for Behavioral Medicine

Willoughby, OH 2021--2024 Behavioral Health
OIG Employing Excluded Individual False Claims
Penalty
$104,007

Outcome

Windsor Laurelwood Center for Behavioral Medicine self-disclosed under its Corporate Integrity Agreement and settled for $104,007.15 for employing an OIG-excluded individual while under active CIA oversight.

Details

Windsor Laurelwood Center for Behavioral Medicine (Willoughby, OH) — Excluded Employee Under Active CIA

Outcome: Settled for $104,007.15 after self-disclosing under its existing Corporate Integrity Agreement that it employed an individual it knew or should have known was excluded from federal healthcare programs.

Windsor Laurelwood Center for Behavioral Medicine, a behavioral health provider in Willoughby, Ohio, employed an individual who was excluded from participation in federal healthcare programs. This occurred while the facility was already under a Corporate Integrity Agreement — a prior compliance obligation triggered by earlier enforcement action, which specifically requires ongoing OIG exclusion screening.

The self-disclosure under the CIA reflects the facility's obligation to report compliance failures discovered through its mandated compliance program activities. Despite this enhanced oversight structure, the excluded-individual employment occurred — demonstrating that CIA compliance requirements alone cannot guarantee effective exclusion screening without automated real-time checking tools.

The settlement of $104,007.15 was finalized July 31, 2025.

Primary Source: Windsor Laurelwood Center for Behavioral Medicine Agreed to Pay $104,000 for Allegedly Violating the Civil Monetary Penalties Law by Employing an Excluded Individual

How Crucible Prevents This

Crucible's automated LEIE screening hooks would catch excluded employees even at facilities under active CIAs; the fact that Windsor Laurelwood — already under CIA oversight — still employed an excluded individual demonstrates that manual CIA compliance cannot substitute for automated monthly exclusion screening.

Source: Windsor Laurelwood Center for Behavioral Medicine Agreed to Pay $104,000 for Allegedly Violating the Civil Monetary Penalties Law by Employing an Excluded Individual

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