Complete Health Partners Holdings will pay $14.1 million to settle allegations that it used unsupported patient diagnoses to increase Medicare Advantage payments.

The Jacksonville, Florida-based company manages and operates affiliated medical groups in Florida, Alabama and Colorado.
Under its contracts with Medicare Advantage insurers, Complete Health received a percentage of the payments those insurers collected from the Centers for Medicare & Medicaid Services. Because CMS pays more for patients coded as having serious medical conditions, Complete Health stood to profit when patient risk scores increased.
According to the Justice Department, Complete Health submitted unsupported diagnoses between 2020 and 2023 involving drug and alcohol dependence, major depression, bipolar disorder and paranoid disorders.
Federal officials alleged that the company distributed incorrect coding guidance, searched medical records for additional diagnoses and prompted physicians to add conditions that were not clinically justified or properly supported.
Those diagnoses increased payments from CMS to Medicare Advantage insurers. The insurers then passed part of the additional money to Complete Health.
The case was brought under the False Claims Act by Karen Bowers, a former associate director of risk adjustment at VIVA Health. Bowers will receive approximately $2.47 million from the federal recovery.
The settlement shows why insiders remain critical to exposing Medicare Advantage fraud. Employees who understand coding guidance, physician prompts, risk-adjustment reviews and payment arrangements may be able to identify when patient conditions are being exaggerated to extract more taxpayer money.



