Fraud & Deception

Premier Family Health and Partners Charged With $24 Million COVID-19 Testing and Telemedicine Fraud

A healthcare entity and its associates billed Medicare and other federal health programs for COVID-19 diagnostic tests and telemedicine consultations using fraudulent orders, generating approximately $24 million in claims for services that were not medically justified or clinically supported.

Premier Family Health, along with multiple associated individuals, was charged in a federal indictment with healthcare fraud conspiracy, false statements, and related offenses connected to a scheme that generated approximately $24 million in fraudulent claims to Medicare and related federal health programs.DOCUMENTED The charges described a scheme that exploited two distinct vulnerabilities created by the COVID-19 pandemic's effect on the healthcare system: the dramatically expanded use of telemedicine for patient consultations, and the federal commitment to covering COVID-19 testing broadly and without cost-sharing to patients.

The defendants are alleged to have used patient data obtained through marketing solicitations to generate telemedicine orders for COVID-19 tests, genetic tests, and other laboratory services without legitimate physician evaluation of the patients named in the orders — submitting claims that described clinical encounters and orders that did not reflect genuine medical interactions.DOCUMENTED

Key facts
  • The alleged scheme generated approximately $24 million in fraudulent Medicare claims
  • Fraudulent orders for COVID-19 testing and telemedicine consultations were billed without genuine clinical encounters
  • Patient data was obtained through marketing solicitations rather than medical referrals
  • Genetic testing and other laboratory services were also included in the fraudulent billing
  • The scheme exploited expanded telemedicine coverage introduced during the COVID-19 pandemic

How the Telehealth Fraud Pattern Operated

The fraud pattern described in the Premier Family Health indictment is representative of a broader category of telehealth fraud that proliferated during the pandemic period.DOCUMENTED Fraudulent telehealth schemes typically involve the acquisition of patient contact information through marketing companies or lead generators, the nominal involvement of a physician or nurse practitioner who signs orders for laboratory or other services without actually evaluating the patients, and the submission of claims that describe these orders as the product of legitimate medical consultations.

In the Premier Family Health case, the patients involved were often solicited with offers of free COVID-19 testing or other services, providing their insurance information in response to these solicitations without understanding that the information would be used to generate fraudulent billing for additional services they neither requested nor received clinical evaluation for.REVIEWED The presence of genuine patient insurance information is what allows these schemes to generate nominally plausible claims that require regulatory investigation to distinguish from legitimate telehealth billing.

The Exploitation of Pandemic Emergency Flexibilities

Federal health programs introduced a range of regulatory flexibilities during the COVID-19 public health emergency to facilitate expanded access to telehealth services. These flexibilities relaxed requirements around in-person physician relationships before telehealth consultations could be billed, reduced documentation requirements in some contexts, and removed geographic restrictions on where telehealth services could be furnished and billed.DOCUMENTED

These legitimate accommodations, designed to ensure that patients could access care without risk of in-person exposure during the early and acute phases of the pandemic, simultaneously created conditions that fraudulent operators exploited. The reduction in prior-relationship requirements made it easier for fraudulent schemes to bill for telemedicine encounters with patients who had no established care relationship with the billing provider — a pattern that would have been more difficult to execute under pre-pandemic telehealth billing rules.REVIEWED

Federal Response to COVID-19 Healthcare Fraud

The Department of Justice coordinated multiple enforcement waves specifically targeting fraud against COVID-19 relief programs and healthcare fraud that exploited pandemic-era policy changes.DOCUMENTED These coordinated takedowns involved parallel prosecutions in multiple federal districts, reflecting the geographic breadth of schemes that used mail, telephone, and internet solicitations to reach patients across the country regardless of where the billing entity was located.

The healthcare fraud enforcement community, including the Health Care Fraud Unit of the DOJ Criminal Division, the HHS Office of Inspector General, and FBI healthcare fraud task forces, has characterized pandemic-related telehealth fraud as one of the largest categories of fraud loss against federal health programs since the programs were established. Recoveries and criminal convictions in this category are expected to continue for years, as complex healthcare fraud investigations routinely take several years from initial identification to final resolution.REVIEWED

Protections for Patients and Program Integrity

Patients who were solicited with offers of free COVID-19 testing, genetic testing, or other services during the pandemic period and who provided their Medicare or insurance information in response should review their Explanation of Benefits statements to verify that claims billed under their information accurately reflect services they received after genuine consultation with a provider they chose.REVIEWED Charges for services that a patient did not request, did not participate in through an actual clinical encounter, or did not receive from a provider with whom they have a clinical relationship can be reported to the program that was billed, which in Medicare's case is the fraud hotline operated by the HHS Office of Inspector General.

Watchdog Journal's secure contact channel is available for individuals who have information about telehealth fraud schemes, COVID-19 testing billing irregularities, or other patterns of false claims against federal health programs.

Telehealth After the Public Health Emergency

The expiration of pandemic-era telehealth flexibilities has narrowed some of the policy openings that schemes like the one alleged against Premier Family Health exploited. Reinstated requirements for prior patient-provider relationships, more stringent documentation requirements for telemedicine orders, and the conclusion of the COVID-19 testing reimbursement environment have all reduced the specific conditions present at the peak of pandemic-related telehealth fraud. However, telehealth as a modality has become structurally entrenched in the healthcare delivery system, and new flexibilities continue to be proposed and adopted as the policy environment evolves. Enforcement attention to telehealth billing fraud remains high within both the DOJ and HHS-OIG, and the investigative tools developed during the pandemic enforcement surge — including data analytics capacity focused on telehealth billing patterns — are expected to remain in use as the telehealth market continues to grow.

Patients who received telehealth consultations or COVID-19 tests through entities they did not independently select — particularly those who were solicited through marketing offers of free testing — and who subsequently received Medicare explanation of benefits statements showing claims for services beyond the testing itself should review those statements carefully. Claims for telehealth consultations that a patient did not participate in, or for laboratory services not discussed with a provider the patient consciously chose, are among the indicators that a patient's insurance information may have been used without full understanding or informed consent, and should be reported through the HHS Office of Inspector General's fraud hotline.

Sources behind this report

  • DOJ indictment and criminal charges, Premier Family Health and associated defendants
  • DOJ press release: COVID-19 healthcare fraud enforcement
  • HHS-OIG guidance on telehealth fraud indicators

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