Heal 360 resolves $20 million uninsured program billing allegations
Oct 11, 2026 edition · GC-2026-0261 · Published 2026-10-11 · Version 4 · Settled
Heal 360 and its owner agreed to a $20 million settlement over alleged billing for office visits during specimen-only COVID testing. The allegations concern services and records, rather than a ban on separately supported clinical evaluations. Liability was not determined.

What happened
DOJ’s October 7 release reports that Heal 360 Urgent Care PLLC, Heal 360 Primary Care PLLC and owner Mohammed Amer Mohiuddin agreed to pay $20 million to resolve False Claims Act allegations. The government alleged unperformed evaluation-and-management services were billed to the HRSA Uninsured Program from January 1, 2021 through March 23, 2022. It distinguishes specimen-collection code 99211 from higher-level office-visit codes, rather than treating a test itself as evidence of an evaluation.
According to the government, walk-up and drive-through patients received specimen collection without other treatment, while template records created the appearance of higher-level visits. Remote scribes prepared records and Mohiuddin appeared as rendering physician on most claims despite not treating those patients. The settlement resolves two whistleblower cases, with a related asset-forfeiture agreement crediting property-sale proceeds toward the civil settlement. These remain allegations without a determination of liability. The control question is whether billed services occurred and the record reflects them.
Scope and timing
- Authority status
- Settled
- Applicability
- Operationally relevant
- Audience
- Health systems, Provider networks
- Jurisdiction
- Federal
Why it matters
The government alleged higher-level office visits were billed instead of specimen collection alone. A testing encounter does not establish that a separately billed evaluation occurred.
Recommended action
Sample encounter documentation against E/M codes and isolate specimen-only visits; retain evidence of services actually performed.
Case details
- agencies
- DOJ, HHS-OIG
- entities
- Heal 360 Urgent Care PLLC, Heal 360 Primary Care PLLC, Mohammed Amer Mohiuddin
- action Type
- Settlement
- event Date
- 2026-10-07
- alleged Conduct
- Alleged E/M billing for services not rendered during January 2021 through March 23, 2022.
- resolution
- $20 million civil settlement; allegations only, with no determination of liability.
Operational lessons
- The government alleged higher-level office visits were billed instead of specimen collection alone. A testing encounter does not establish that a separately billed evaluation occurred.
- Sample encounter documentation against E/M codes and isolate specimen-only visits; retain evidence of services actually performed.
Sources
- Heal 360 resolves $20 million uninsured program billing allegationsOfficial · DOJ · 2026-10-07 · Source review 2026-10-11
Complete edition and supplemental material
This finding in the complete approved report →Regulatory horizons, CIA trends and implementation trackers remain in the full report.
Read the entire Enforcement Briefing report →