Centurion Labs: The COVID Testing Company the DOJ Charged With Billing Medicare for Tests That Were Never Ordered

Centurion Laboratories LLC and its principal officers faced Department of Justice criminal charges alleging the laboratory submitted tens of millions of dollars in false claims to Medicare for COVID-19 tests and respiratory pathogen panels that were never ordered by the treating physicians whose names appeared on the claims and, in many cases, never administered to the patients for whom the claims were filed — a category of fraud that exploited the federal government's emergency authorization of expanded COVID-19 testing reimbursement during the public health emergency.DOCUMENTED

The Centurion case was part of a broader DOJ and HHS Office of Inspector General enforcement campaign targeting COVID-19 testing fraud, an area that proved particularly susceptible to exploitation because the federal government's public health response included rapidly expanded reimbursement for testing without the prior authorization controls that normally govern Medicare billing for laboratory services.

How COVID Testing Fraud Operated

Medicare reimbursement for laboratory services typically requires a physician order — documentation that a treating physician has ordered the specific test for the specific patient as part of their medical care. During the COVID-19 public health emergency, certain testing flexibilities were introduced, including expanded coverage for testing without the typical prior authorization requirements. These flexibilities, designed to facilitate rapid scaling of testing capacity, also reduced some of the documentation barriers that normally make it more difficult to submit fraudulent laboratory claims at scale.REVIEWED

Laboratory fraud operations that targeted COVID-19 testing reimbursement typically operated by obtaining patients' Medicare beneficiary information — through health fairs, telemarketing, or purchased patient data — and billing for tests without actually administering them, or by billing for more expensive multi-pathogen panels when only a basic COVID test had been performed. The most egregious operations, like the scheme alleged against Centurion, went further: using physician identifiers obtained without the physicians' knowledge or consent to create facially plausible ordering documentation for tests that never occurred in any form.DOCUMENTED

Physician Identity Theft in Healthcare Fraud

The use of physician National Provider Identifiers — the numbers assigned to healthcare providers for billing purposes — without the physicians' knowledge or authorization is a form of identity theft that is a recurring element in large-scale Medicare fraud schemes. Physicians whose NPIs are used in fraudulent billing may discover the misuse when they receive remittance notices for claims they did not submit, or may not discover it at all unless audited or contacted by investigators. The harm to the physicians extends beyond the inconvenience of responding to investigations — their professional reputations can be affected by the appearance of fraudulent billing in their names, and their ability to participate in Medicare programs can be disrupted by the audit activity that follows identification of fraudulent claims.REVIEWED

The DOJ's charges against Centurion included identity theft counts related to the misuse of physician NPIs — reflecting the criminal law's recognition that obtaining and using another person's identifying information to commit fraud is a separate offense from the underlying fraud itself. These counts added both additional criminal exposure and additional victim categories — the physicians whose identities were appropriated — to what was already a substantial healthcare fraud prosecution.

COVID testing fraud didn't just steal from Medicare. It put real physicians' names on fraudulent claims without their knowledge, turning their professional identities into instruments of a crime they had nothing to do with.

The Scale of COVID Testing Fraud

The DOJ and HHS-OIG's enforcement campaign against COVID-19 testing fraud recovered billions of dollars in fraudulently obtained funds and resulted in hundreds of prosecutions across the country. The Centurion case represented one instance of a pattern that emerged across multiple jurisdictions: laboratory operations established during the pandemic using the expanded testing reimbursement framework as an opportunity for rapid, high-volume fraud. The ease with which Medicare could be billed for laboratory services, combined with the high per-test reimbursement rates established during the public health emergency, created conditions that attracted both opportunistic fraud by existing healthcare businesses and the establishment of new entities created specifically to exploit the temporary reimbursement environment.DOCUMENTED

The government's response to COVID testing fraud was among the more aggressive healthcare fraud enforcement campaigns in recent memory, reflecting both the scale of the financial losses and the policy concern that exploitation of public health emergency resources undermined the integrity of the testing infrastructure that was central to the government's COVID-19 response strategy. Individuals charged in COVID testing fraud cases faced the full range of healthcare fraud penalties — up to 10 years per count for healthcare fraud, up to 20 years for wire fraud, and additional consecutive sentences for identity theft counts — with courts in several jurisdictions handing down substantial sentences that reflected the deliberate exploitation of an emergency program designed to protect public health.

Protecting Medicare From Future Testing Fraud

The COVID testing fraud enforcement campaign produced recommendations for systemic changes to Medicare's laboratory billing systems designed to reduce the vulnerability the emergency authorization had exposed. These included enhanced pre-payment review for laboratory claims that show patterns inconsistent with legitimate ordering relationships — for example, claims attributed to physicians who have no documented relationship with the laboratory or who are physically located far from the patients being tested. The Centers for Medicare and Medicaid Services implemented additional prior authorization requirements for certain high-risk laboratory tests and enhanced data analytics to identify billing patterns consistent with fraud before payment is issued rather than through post-payment audit. For the long term, the COVID testing fraud experience reinforced the value of the prior authorization controls that were relaxed during the emergency — controls that, while creating friction in the legitimate billing process, provide a meaningful check against the type of wholesale fabrication that Centurion and similar operations engaged in at scale. Medicare fraud prevention is inherently a tension between efficient payment processing and fraud control, and the COVID experience provided a natural experiment in what happens to that balance when the fraud control elements are substantially reduced under emergency pressure.

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