Heal 360 Urgent Care PLLC, Heal 360 Primary Care PLLC, and their owner Dr. Mohammed Amer Mohiuddin have agreed to pay $20 million to resolve False Claims Act allegations arising from a systematic billing fraud against the Health Resources and Services Administration’s COVID-19 Uninsured Program. According to the allegations, the Heal 360 clinics operated walk-up and drive-through COVID-19 testing sites across Texas where patients received nothing more than a nasal swab for specimen collection. Despite that, the clinics submitted hundreds of thousands of claims using elevated Evaluation and Management CPT codes reserved for substantive physician consultations, that were reimbursed at rates far higher than a simple specimen collection would have commanded. To support those inflated claims, overseas remote scribes generated fictitious medical records purporting to document clinical encounters that never actually took place.
Two separate whistleblower lawsuits brought the scheme to light. The first, U.S. ex rel. Hooper et al. v. Heal 360 Primary Care, PLLC et al., was filed in the Eastern District of Texas; the second, U.S. ex rel. Hasan v. Heal 360 Urgent Care, PLLC et al., was filed in the Northern District of Texas. Investigators from HHS-OIG, the DOJ Civil Division, and the U.S. Attorney’s Offices for both the Northern and Eastern Districts of Texas all participated in the matter. The whistleblowers who filed those suits and whose inside knowledge made the case possible will collectively receive $3.4 million from the settlement proceeds.
The case illustrates the particular vulnerability of emergency relief programs, designed to move money quickly and with reduced administrative friction, on billing schemes that exploit the gap between what was documented and what was delivered. The HRSA COVID-19 Uninsured Program was created specifically to ensure that uninsured patients could access testing and treatment without cost barriers; the allegations here describe that program being used as a vehicle for submitting fabricated claims dressed up with manufactured clinical records.