Fifteen Days to Show Your Work
- Aug 7
- 2 min read
Earlier this summer, federal prosecutors charged 455 people in connection with $6.5 billion in alleged healthcare fraud.
The scale made headlines. What matters more is what the cases have in common: recurring documentation gaps, referral arrangements, and billing patterns.
In practice, that meant falsified therapy notes, back-dated medical records, and claims for visits that never occurred. It also meant kickbacks to marketers for medically unnecessary social adult day care services, beneficiaries paid outright for the use of their Medicaid numbers, and counseling and therapy billing volumes that no staff could have delivered even if all providers were working 24 hours per day.
This same type of behavior drove a second set of consequences. Alongside the criminal charges, CMS suspended 1,079 providers and revoked billing privileges for 1,403 providers. There were more than 1,400 provider exclusions, 48 civil monetary payment settlements totaling over $73 million, and 25 HHS-OIG actions under the Civil Monetary Penalties Law seeking more than $10 billion. The administrative track moved quickly.
It’s important to remember that a payment suspension does not wait for an organization to be adjudicated guilty. Medicare payments can be suspended on a credible allegation of fraud rather than a proven one and under 42 C.F.R. § 405.372, prior notice is not always required.
The first chance to respond to a payment suspension notice is not a trial. It is a written rebuttal, generally due within 15 days.
Fifteen days is not enough time to build a compliance record. It’s only enough time to produce one.
When regulatory scrutiny arrives, organizations point to their compliance programs. What matters is whether the compliance program has anything to point to. An organization with an effective compliance program can provide evidence as a matter of routine which can narrow an administrative enforcement action, shorten it, or keep it from starting in the first place. A company without it will begin the same race fifteen days late.
The evidence an effective compliance program already has on hand:
Audit reports showing billing patterns were reviewed and any necessary corrective action that followed.
Clinical records showing the services were delivered.
Vendor agreements and compensation records showing lawful structures and documented due diligence.
Exclusion screening logs with dates, results, and escalation records.
Regulatory scrutiny can arrive in more than one form. The 2026 National Health Care Fraud Takedown put both tracks on display at once with hundreds of criminal defendants and alongside them, more than a thousand suspensions, over a thousand revocations, and more than 1,400 exclusions. An organization cannot control which form scrutiny takes. It can control whether its compliance program has already been doing the work to respond to it.
Catapult Healthcare Consulting, LLC brings a former HHS-OIG attorney's perspective to compliance program assessments for healthcare organizations. If you want to discuss what an assessment would look like for your company, connect with us.
