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Billing fraud & false claimsNew in this edition

Heal 360 resolves $20 million uninsured program billing allegations

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.

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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.

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

Complete edition and supplemental material

This finding in the complete approved report →

Regulatory horizons, CIA trends and implementation trackers remain in the full report.

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