News and Insights

Visit regularly for up-to-date information on relevant news, firm announcements and additions to our AZ Health Law Blog.

Written by: Desalina Williams

On August 11, 2021, the U.S. Department of Justice (DOJ) issued a press release announcing a $350,000 settlement between the federal government, Cornell Scott Hill Health Corporation (“Cornell”), a Federally Qualified Health Center (“FQHC”), and the State of Connecticut to settle Medicaid fraud claims asserted against Cornell.

As a FQHC, Medicaid pays Cornell for certain services on an “encounter-based” reimbursement structure. Per federal law, claims for dental services, paid on an encounter-basis, are limited to one all-inclusive encounter per day, which should include all dental services rendered to a patient during his or her visit. The government alleged that Cornell improperly billed Connecticut’s Medicaid program for prophylactic cleaning and dental exams by requiring Medicaid patients to receive prophylactic cleanings and dental exams on different days so that Cornell would receive payment for two encounters instead of one. To resolve the allegations against it, Cornell paid $350,000 to the federal and Connecticut state governments. It also agreed to change its policy by offering Medicaid patients the option of scheduling their prophylactic cleaning and dental examination for the same day.

Earlier this year, in a January 2021 press release, the DOJ announced that it obtained more than $2.2 billion in settlements and judgments from civil fraud cases in the fiscal year that ended in September 30, 2020. $1.8 billion of that amount represented federal losses that were recovered from the health care industry. Many cases also included the recovery of millions of dollars for state Medicaid programs. This recent settlement with Cornell should prompt healthcare providers who are serving Medicaid beneficiaries to proactively assess their billing practices and policies to ensure that their policies are compliant with federal and their state’s Medicaid laws.

To review the August 11, 2021 Press Release from the U.S. Department of Justice, visit