As we shared in Part One on this topic [link], in late July of this year the Department of Health and Human Services Office of Inspector General (OIG) released a Special Fraud Alert regarding “Telemedicine Companies”[1] that addressed problematic arrangements leading to a material incidence of fraud following dozens of fraud investigations in the last two years. In this Part Two, we highlight a few of the recently announced criminal cases initiated by the OIG that are said to have resulted in more than $1.2 billion in losses to the federal government—all primarily involving allegations of bribery and illegal kickbacks with Telemedicine Companies.
The telemedicine industry has exploded in recent years, primarily as a result of the changes to healthcare delivery models necessitated by the coronavirus pandemic. One of only six such communications in nearly 20 years,[2] the OIG’s latest Special Fraud Alert is connected to its announced collaboration with the United States Department of Justice (DOJ) to combat the troubling incidences of telemedicine fraud. On July 20, 2022, the DOJ announced federal charges against 36 criminal defendants in 13 different districts for healthcare fraud violations involving, primarily, alleged bribery and illegal kickbacks between Telemedicine Companies and physicians.[3] The nationwide coordinated effort also included participation from the Federal Bureau of Investigation, the Centers for Medicaid and Medicare Services (CMS), the Internal...
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