Michigan surgeon accused of $60M billing fraud


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An indictment unsealed July 10 charges Vasso Godiali, MD, with orchestrating a $60 million healthcare fraud scheme and laundering proceeds from the scheme, according to the Department of Justice.

Dr. Godiali, a vascular surgeon, allegedly submitted false claims to Medicaid, Medicare and Blue Cross of Michigan for services that weren’t provided and exploited Modifier 59 to improperly unbundle claims. Dr. Godiali allegedly claimed he was performing several separate procedures when he was only entitled to a single reimbursement for a single procedure, according to the Justice Department.

The indictment further alleges Dr. Godiali used six corporations to launder roughly $49 million in proceeds from the healthcare fraud scheme, according to the Justice Department.

Dr. Godiali faces a maximum sentence of 10 years in prison for the healthcare fraud charge and a maximum sentence of 20 years in prison for money laundering, according to the Justice Department.



Hospital Pass-through Billing Scheme Detailed in Florida Plea Agreement


Kyle Marcotte of Jacksonville Beach admitted to using rural hospitals in a scheme that kicked back more than $50 million in insurance reimbursements for urine tests.


Marcotte, the owner of a substance abuse treatment facility, sent his patients’ urine samples to a lab that retuned 40% of the insurance reimbursements to Marcotte. 

The lab owner then arranged with the managers of two rural hospitals in Florida to have the testing billed to private insurers at a better reimbursement under the hospitals’ in-network contracts.

The scheme expanded to include rural hospitals in Georgia, and more drug rehab centers, and laundered more than $57million in illicit reimbursements.

The owner of a Florida substance abuse treatment center pleaded guilty Tuesday to his role in a pass-through billing scheme that used rural hospitals to launder millions of dollars, the Department of Justice said.

Kyle Ryan Marcotte, 36, pleaded guilty to one count of conspiracy to commit money laundering and agreed to forfeit $10.2 million. His sentencing date has not been set, DOJ said.

According to DOJ, Marcotte, the owner of a substance abuse treatment facility in Jacksonville Beach, Florida. In 2015, Marcotte sent his patients’ urine samples to a lab that retuned 40% of the insurance reimbursements to Marcotte.

The lab owner then arranged with the managers of Campbellton–Graceville Hospital and Regional General Hospital Williston in Florida to have the testing billed to private insurers through the rural hospitals at a better reimbursement under the hospitals’ in-network contracts, DOJ said.

Attempts by HealthLeaders’ to contact officials at Campbellton–Graceville Hospital and Regional General Hospital Williston for comment were not successful.

Marcotte also admitted that he brokered deals with other substance abuse treatment centers to have their urine tests billed through the two hospitals in exchange for Marcotte receiving 10% of the insurance reimbursements. The other rehab centers received 30% of the reimbursements, DOJ said.

The lab owner, who was not identified by DOJ, then acquired Chestatee Hospital, in Dahlonega, Georgia, and other rural hospitals, and Marcotte continued to supply samples from his rehab facility and brokered deals with other substance rehab facilities that used those hospitals, DOJ said.

The reimbursements were sent from the hospitals to the lab, which sent them to two companies Marcotte controlled, North Florida Labs and KTL Labs.

Marcotte used the reimbursements from KTL Labs to pay $50 million in kickbacks to at least 88 companies and people operating other rehab facilities who involved in the scheme.  The total amount of money involved in the laundering scheme was $57.3 million, DOJ said.




Out-of-pocket costs rising even as patients transition to lower-cost care settings


Patients saw increases of up to 12% in their out-of-pocket responsibilities for inpatient, outpatient and ED care in 2018.

A new TransUnion Healthcare analysis has found that most patients likely felt a bigger pinch to their wallets as out-of-pocket costs across all settings of care increased in 2018. The new findings were made public yesterday at the 2019 Healthcare Financial Management Association Annual Conference in Orlando.

The analysis reveals that patients experienced annual increases of up to 12% in their out-of-pocket responsibilities for inpatient, outpatient and emergency department care last year.

In 2017, the average inpatient cost was $4,068; the average outpatient cost was $990; and the average emergency department cost was $577.

In 2018, the average inpatient cost was $4,659; the average outpatient cost was $1,109; and the average emergency department cost was $617.


There are certain factors that are influencing this trend, according to Jonathan Wiik, principal of healthcare strategy at TransUnion Healthcare.

“Patients are becoming more aware that emergency care is expensive and somewhat inefficient,” Wiik said. “No one wants to go to the emergency room unless we have to, because we don’t want to deal with the time there or the expense. They aren’t the best place to get primary or even urgent care.”

Another factor, he said, is that providers realize the emergency department is a care setting of last resort for many. Providers want to make sure that have room in the ED for cases that are real emergencies, so they’re essentially curating their patients, steering patients to the most cost effective settings possible — often primary care, which is the least expensive setting.

Noting that the biggest annual increases were in inpatient and outpatient care, Wiik said that was largely a function of utilization and just a general wariness, in addition to the fact that most EDs have pretty flat contracts. Financial communication with patients is also an issue.

“Most people can’t afford the average out-of-pocket, so providers are really trying to educate patients as early as they can about those costs,” said Wiik. “Emergency care is a really hard place to educate people on finances, let alone collect on them.”


The analysis found that, during a hospital visit, patients are likely experiencing cost increases that continue the trend of higher out-of-pocket costs. About 59% of patients in 2018 had an average out-of-pocket expense between $501 and $1,000 during a healthcare visit. This was a dramatic increase from 39% in 2017. Conversely, the number of patients that had an average out- of-pocket expense of $500 or below decreased from 49% in 2017 to 36% in 2018.

And with out-of-pocket costs increasing, the trend toward consumerism is growing as more patients, payers and providers transition to lower cost settings of care.

One example: Inpatient care, traditionally the most expensive healthcare option, has seen a leveling off with the percentage of price estimates remaining at 8% between 2017 and 2018. The percentage of outpatient services estimates, generally about one-quarter of the cost of inpatient services, rose in that same timeframe from 65% to 73%.

“Patients are likely seeing more providers and payers recommending that they take advantage of cost-effective healthcare options, which brings down costs for all parties,” said Wiik. “This is especially important as costs continue to rise in all areas of healthcare, particularly in inpatient, outpatient and emergency department services.”

This is having an impact on providers, payers and patients, he said.

“Let’s pretend Joanna had an MRI in her head, and that ran $3,200. That might have been paid by Blue Cross Blue Shield, and $100 out of Joanna’s pocket. Now Joanna’s paying $300. Most patients don’t look up how much the MRI’s going to be. They just get the bill later and try to figure it out. I think the patient portion of the bill is going to be in the 35, 40% range very soon. What that means is we’re quickly approaching half of the bill coming from the patient and half from the payer. That’s not insurance anymore, that’s a bank account.”

A recent Kaiser Family Foundation study indicated that 34% of patients are finding it difficult to pay their deductible before insurance kicks in. In addition to patients being challenged to make payments, the trend is that providers are also feeling the pressure of increased denial rates and write-offs, which is increasing bad debt.

Considering these factors together — increased out-of-pocket expenses, a patient’s challenge to make payment, and increased denial rates — collecting payments from all payers is critical for providers. In order for providers to ensure they receive payment for the patient-care services rendered, it is vital that they implement strategies that maximize reimbursements.



Hospitals as medical debt litigators


Illustration of rope lassoing a hospital bill.

Tax-exempt hospitals are again raising eyebrows over how they harass patients, often the poorest, in court by trying to recoup medical debts, my colleague Bob Herman writes.

Driving the news: ProPublica and MLK50 published a deep dive yesterday on Methodist Le Bonheur Healthcare, a $2 billion not-for-profit and faith-based hospital system in Tennessee that has filed more than 8,300 lawsuits against patients over the past 5 years.

  • One of the patients featured in the story made less than $14,000 last year, and Methodist is suing her for more than $33,000. The hospital operates in the second-poorest large metropolitan area in the nation.
  • Methodist obtained wage garnishment orders in almost half of the cases it filed between 2014 and 2018, meaning that the debtor’s employer was required to send the court a portion of the worker’s after-tax income.

Between the lines: As we wrote this week, hospitals taking patients to court is both common and longstanding.

The bottom line: Not-for-profit hospitals market themselves as charities, but they act more like for-profit peers — renewing questions of whether those organizations’ tax exemptions are justified.

  • Coincidentally, the American Hospital Association released a paper Thursday touting hospitals’ community benefits, but the paper has some of the same flaws as prior analyses.

What we’re watching: These practices have drawn the ire of Sen. Chuck Grassley, who is now chairman of the powerful Finance Committee.

  • “Such hospitals seem to forget that tax exemption is a privilege, not a right. In addition to withholding financial assistance to low-income patients, they give top executives salaries on par with their for-profit counterparts,” Grassley wrote in a 2017 op-ed.




Piedmont now requires 25% advance payment for self-pay patients


Piedmont Healthcare is taking a bold approach in its fight against bad debt: The not-for-profit health system now requires patients who’ll be on the hook for the entirety of their bill to pay one-quarter of it before they can receive non-emergent services.

Atlanta-based Piedmont launched the advance payment policy this month. It requires uninsured, self-pay patients and those with high-deductible commercial policies to pay 25% of their bill before they can receive services.

“To move to point-of-service collections is a big shift,” said Joseph Fifer, CEO of the Healthcare Financial Management Association. “To do it even beforehand, that’s even a bigger movement, given where we’re starting from.”

Leaders from Piedmont’s revenue-cycle team told Modern Healthcare in an interview at the HFMA’s annual conference in Orlando, Fla., that the new policy is the latest phase in what has been five years of improved patient education around out-of-pocket costs, including sending patients price estimates—even if patients didn’t ask for them—prior to almost all services.

But they acknowledge not everyone will welcome the change.

“As much as people in healthcare want transparency, they get uncomfortable when you start talking about requirements for things, because requirements mean that a patient may hear ‘no’ to their healthcare,” said Andrea Mejia, Piedmont’s executive director of patient financial care and revenue cycle, “so that gets controversial.”

Like many of its peers, 11-hospital Piedmont shoulders a heavy bad-debt load, or bills that go unpaid that the system expected to be paid, as health insurers increasingly require patients to foot bigger portions of their bills.

The health system’s $250.7 million bad-debt expense in fiscal 2018 was about 8% of its $3 billion in revenue that year—up from 6.5% of revenue the prior year and much higher than the 2% national average the American Hospital Directory calculated in 2017.

Not-for-profit hospitals’ bad debt is projected to increase at least 8% this year as the high-deductible health plan trend continues, according to Moody’s Investors Service.

Requiring upfront payment is relatively common at physician practices. Some hospitals likely employ the tactic, too, but they’re unlikely to publicize such policies, said Jonathan Wiik, healthcare strategy principal with TransUnion Healthcare.

The HFMA’s Fifer said he couldn’t think of examples of other health systems that have implemented blanket pre-pay policies like Piedmont’s, and said he doesn’t think it’s prevalent.

He called it a “major shift” in an industry that’s long been too focused on back-end collection.

UPMC in Pittsburgh earlier this month scrapped its plan to seek pre-payment from out-of-network Highmark Medicare Advantage members once the academic health system’s consent decrees with Highmark end on June 30.

Effect on access

Piedmont’s Mejia said the policy’s potential to dissuade patients from receiving necessary care for serious conditions is “a very legitimate concern.”

The policy raises red flags, said Berneta Haynes, senior director of policy and access with the consumer advocacy group Georgia Watch. She said she fears it could hamper access to care and take away patients’ ability to negotiate. “It does have the potential to become a real impediment for folks seeking healthcare,” she said.

It’s not unheard of for hospitals to create pre-payment rules, said Mark Rukavina, business development manager in Community Catalyst’s Center for Consumer Engagement in Health Innovation. When they do, leaders need to ensure the rules don’t create barriers to care. That means screening for financial assistance, informing patients of the financial assistance policy and making exceptions when necessary, such as for cancer patients.

“These kinds of payments, especially if you’re dealing with larger bills, are certainly going to have a chilling effect on people and their willingness or ability to access care,” Rukavina said.

Brian Unell, Piedmont’s vice president of revenue cycle, said the new advance payment policy allows Piedmont’s physicians to escalate cases to administration in situations where patients need care urgently, such as for cancer treatment.

“That’s been the biggest lesson learned so far and pushback we’ve gotten,” he said.

There’s currently no ceiling amount on what patients could be forced to pay before receiving services, but Unell said the system would probably make an exception if 25% ended up being $2,500, for example. Piedmont discounts its billed charges by 70% for self-pay patients.

Final step in collections

The new policy is the third in a three-phase collection policy Piedmont has implemented since late 2017. The first phase was 15% pre-pay requirement for walk-in visits, including lab tests and X-rays. It did not apply to the system’s urgent-care clinics. Officials said they wanted to implement the policy in few facilities. The second phase expanded the 15% requirement to scheduled services like surgeries.

For policies like Piedmont’s to be successful, they need to have very good relationships with their referring physicians, TransUnion’s Wiik said. The rub tends to enter when physicians argue that their patients aren’t getting medically necessary services, he said.

In Piedmont’s case, the policy also has the unintended effect of competing with its physicians, some of whom have their own pre-payment policies, Unell said.

Wiik argues that if patients were truly unable to pay the bill, the hospital’s financial assistance policy or Medicaid eligibility would kick in.

“Do you have an inability or an unwillingness to pay?” he said. “There’s a difference.”

Policies like Piedmont’s can be tricky, but the benefit is that they find patients who really can pay who may not have otherwise paid, Wiik said.

While one goal of Piedmont’s policy is probably cash flow, the HFMA’s Fifer said his hunch is the primary driver is engaging patients in a conversation about financial responsibility.

Piedmont has increased its same-store, upfront collections by about 500% since 2014 thanks to revenue cycle improvements it has made in that time, Unell said. The health system has also expanded its back-end patient financing options, including moving more toward monthly payments. The system does not offer discounts to patients who agree to pay in a lump sum right away.

Unell described Piedmont’s revenue-cycle work as a journey, and said the system is constantly evolving based on new information.

“None of this is easy,” Unell said, “and by no means do we have it figured out.”




Bon Secours Mercy Health to sell majority stake of RCM to PE firm


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Bon Secours Mercy Health plans to sell a majority stake of its revenue-cycle management subsidiary Ensemble Health Partners to private equity firm Golden Gate Capital, the organizations announced Thursday.

The Cincinnati-based Catholic health system aims to sell 51% of the equity in Ensemble netting $1.2 billion in cash proceeds, which will be reinvested in Bon Secours Mercy when the deal is completed following the standard regulatory approvals.

“Our bread and butter is not to be a revenue cycle management company, so we thought maybe it was time to spin it out as a private company,” said John Starcher, Bon Secours Mercy Health president and CEO, adding that Golden Gate has the capital and expertise to continue to build out Ensemble.

Founded in 2014, Ensemble has grown to 3,600 employees in 30 states that serve 27 health systems. Then-Mercy Health acquired Ensemble in 2016, when it worked with about eight health systems, and invested around $60 million.

At that time, Mercy was coming off a failed revenue cycle outsourcing venture and an attempt to bring it in-house as its cost to collect, point of service collections and other metrics were trending negatively, resulting in a $135 million shortfall in expected cash collections, Starcher said.

Ensemble has helped Mercy Bon Secours accrue about $400 million to its bottom line over a three-year period, he said.

“Our terrible numbers had righted in less than one year,” Starcher said.

More providers are outsourcing their scheduling, billing and collections services as patients shoulder more of their healthcare costs and bad debt levels grow. Hospitals and health systems are turning to specialists that claim to deliver on patient satisfaction goals, which are poised to have a greater impact on reimbursement rates. Outsourcing also allows providers to free up capital and mitigate compliance risks.

“There is a tremendous amount of pricing and rate pressure on health systems,” said Judson Ivy, founder and CEO of Ensemble, adding that consumerism is another driving force behind outsourcing revenue cycle management as consumers seek a better experience. “There is also a talent drain on the industry.”

Meanwhile, alternative revenue sources are becoming a bigger part of hospital and health systems’ strategies. Ninety percent of hospital and health system executives in a recent survey indicated that new revenue streams were an urgent priority and expected to yield a return in the next three years, a study from Boston-based Partners HealthCare and healthcare private equity firm Fitzroy Health found.

Pressure on reimbursement rates from government and commercial payers have driven investment in revenue cycle subsidiaries, commercial real estate ventures, consulting spin offs, supply chain companies and other endeavors.

Bon Secours Mercy Health also has an IT subsidiary that specializes in Epic installations and a call center venture that manages the patient journey, among others, Starcher said.

“We also have expertise as we look across the continuum in marketing, supply chain and HR, and we think this is a burgeoning opportunity,” he said.

But you can’t monetize a mediocre service, Starcher said, offering a word of caution. A subsidiary can’t be so tethered to a health system that it can’t be priced competitively with other standalone companies, he said.

“While many health systems talk about this a lot, it doesn’t mean that it has been done successfully,” Starcher said.

Mercy Health and Bon Secours Health System completed their merger in September 2018, expanding its combined network to 43 hospitals, more than $8 billion in net operating revenue and 57,000 employees.

Over a four-month period following the merger, the health system reported $58.9 million in recurring operating income, which excludes restructuring and integration expenses, on operating revenue of $2.7 billion. With the $95.5 million of one-time costs, its operating income fell to negative $36.6 million. Those losses included an impairment charge on the now-defunct HealthSpan Partners’ investment in Summa and merger-related costs.

That compared to $72.9 million in recurring operating income on revenue of $2.69 billion over the same period the year prior. Operating income fell slightly to $68.2 million with $4.7 million of one-time expenses.


Not-for-profit hospitals are financially resilient due to strong management, S&P Global Ratings says.


The broad balance sheet shows hospitals are improving financial strength and flexibility compared to two decades ago.

Not-for-profit hospitals and health systems are financially keeping up with changes in the healthcare landscape, according to a new S&P Global Ratings report.

S&P Global Ratings said it believes the not-for-profit healthcare sector has been incredibly resilient over the past two decades, in large part due to strong management and governance.

The broad balance sheet shows improved financial strength and flexibility compared to two decades ago, as is also the case for maximum annual debt service coverage.

Hospitals have done this throughout a time when changes in government policy, reimbursement and the move to value-based care have been factors in their operating performance and financial position. The report shows more variability in operating revenue and excess margins. 

S&P Global looked at providers rated from BBB+ to AA. The stronger providers have seen margin improvement, while weaker rated providers have been generally stable with some pockets of weakness at the lowest reported rating levels, the report said.


Health system challenges include increasing levels of competition and disruption; consumerism and the heightened focus on quality measures and outcomes; the rapid growth in technology and big data analytics; the rise of population health and changes in payment delivery models; and a fundamental shift in how and where patients are treated.

“To be successful, provider management teams must adapt and adjust or run the risk of being left behind,” the credit analysts said.

A factor benefiting health systems has been the low interest rate environment. This has allowed hospitals to finance strategic capital assets, while keeping carrying costs at very manageable levels.

Industry consolidation has had a favorable impact on enterprise profiles, the report said.  While ample “horizontal” competition exists for both hospitals and health systems, in many markets consolidation has made it more manageable.

But competition between hospitals and health systems and new market entrants seeking to control niche services or some aspect of ambulatory care services is presenting new and rapidly evolving threats to enterprise profiles, the report said.


Net patient service revenue has risen across all S&P rated categories for both stand-alone and system providers. This is due to a variety of reasons, including the addition of more business lines such as physician and insurance services, and increased industry consolidation;

Operating and excess margins are more complicated, highlighting the ebb and flow of industry trends, including increased joint venture and affiliation activity and investment market volatility.

Maximum annual debt service coverage has grown in all but the weakest rated levels, highlighting an improving balance between operational performance and debt.

Growth in days’ cash on hand has been a universal success even as capital expenditures remain robust.

Debt levels have been favorable with an improved cushion ratio and declining debt as a percentage of capitalization, both well-established trends.


Momentum continues to build for major legislative and regulatory changes at both the national and state level.

Many of the hospitals and health systems in S&P Global’s rated portfolio have navigated through numerous changes. Historically, a review of ratios over time demonstrates that providers have responded well to change as a group, although results have varied among individual organizations.

While credit quality can and will change over time,  the majority of the rated portfolio is well-positioned to compete effectively as new strategies are required, the analysts said.

S&P Global Ratings analyzes and publishes not-for-profit healthcare median ratios annually, and has been doing so for over 20 years.


“In our view, senior leadership and management teams have provided guidance and direction through a series of difficult and changing periods and have emerged as generally stronger organizations from a financial profile standpoint,” the credit analysts said. “We believe the vast majority of rated hospitals and health systems have the financial discipline and expertise to navigate the challenges over the next decade and beyond, and while there may be some movement in underlying trends in these key metrics, the overall financial outlook, barring any significant shocks from policy or macroeconomic shifts, should remain generally consistent.”