Dr. Pearson has recently been hired into the Central City Internal Medicine Group as its fifth physician. He has recently completed his residency and is eager to enter private practice. Dr. Pearson is introduced to Meredith and Dawn, two members of the billing staff for the practice. Unbeknownst to Dr. Pearson, Meredith financially assists the practice in several ways. She bills procedures by using individual codes instead of comprehensive codes, has decided to bill Dr. Pearson’s services under the Medicare number of Dr. Craig (another Central City physician) until Dr. Pearson’s credentialing process has been completed, and habitually submits a claim more than once if she isn’t sure whether it has already been submitted or not.

1. Name the types of fraudulent billing that Meredith is conducting.

2. Could Meredith be held liable for these activities? (Explain)

3. Is Dr. Pearson subject to liability although he doesn’t know Meredith is conducting these activities? (Explain)

4. Is Dr. Craig subject to liability because his Medicare number is being used inappropriately? (Explain)

5. Is Dawn subject to liability as a co-worker (and fellow biller) of Meredith’s? (Explain)

6. Once Meredith’s activities are discovered, how should her conduct be handled by her employer, Central City Internal Medicine?

7. Once Meredith’s activities are discovered by the OIG, what sanctions can be expected? 8. What should Central City do to ensure these types of problems don’t occur in the future?