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Villages Health System agreed to pay $541.5 million to settle allegations it submitted false diagnosis codes to Medicare Advantage plans between 2020 and 2024, inflating payments from the government. The company self-disclosed the scheme and cooperated with investigators, which reduced what could have been a larger penalty.
- TVH submitted unsupported or improperly documented diagnosis codes to three major insurers (Humana, UnitedHealthcare, Blue Cross/Blue Shield), causing CMS to overpay the plans, which then overpaid TVH under their capitated contracts.
- The diagnosis codes lacked adequate medical record support or were based on unauthorized amendments to patient records, violating False Claims Act requirements that diagnoses must be supported by face-to-face visits and affect patient care.
- TVH's self-disclosure through the HHS-OIG's fraud reporting protocol and full cooperation with the government investigation earned them credit that reduced their settlement liability, though the company filed for Chapter 11 bankruptcy in July 2025.