On September 24, 2025, United States Attorney Pete Serrano announced that an urgent care clinic with locations in Richland and Pasco, Washington, had agreed to pay $2,807,729 to resolve claims that it fraudulently overbilled Medicare and Medicaid for diagnostic tests.
According to the settlement agreement, the claims arose under the False Claims Act (FCA) from allegations that the clinic fraudulently billed for polymerase chain reaction (PCR) respiratory and urinary tract infection panel testing. These panel tests involve a predetermined group of medical tests used to detect multiple pathogens from a single patient sample.
The United States and the State of Washington alleged that, rather than billing for a single panel test, the clinic improperly “unbundled” the tests—billing separately for each component. This practice allegedly resulted in overbilling Medicare and Medicaid. Additionally, the State of Washington alleged that the clinic billed for more expensive panel tests that were not medically necessary for certain patients, such as those presenting with Covid-19 symptoms.
The settlement followed a joint investigation conducted by the United States Attorney’s Office, the Washington State Attorney General’s Office, and the US Department of Health and Human Services Office of Inspector General (HHS-OIG).
“It is critical for providers to bill Medicare, Medicaid, and other taxpayer-funded healthcare programs lawfully and accurately. The submission of false laboratory testing claims diverts key resources away from those who rely on them, including the elderly and low-income families,” said Jeffrey C. McIntosh, Acting Special Agent in Charge with HHS-OIG. “HHS-OIG remains committed to working with our law enforcement partners to safeguard federal healthcare programs for the benefit of the American people.”
Compliance Perspective
Issue
It is illegal to submit claims for payment to Medicare or Medicaid that you know, or should know, are false or fraudulent. Filing false claims may result in fines of up to three times the program’s loss, plus penalties of over $11,000 per claim. Under the civil False Claims Act, each instance of an item or service billed to Medicare or Medicaid counts as a separate claim—meaning fines can escalate quickly. Facility staff must be knowledgeable about how to identify and report suspicious billing practices. A nonretaliatory environment for reporting these concerns is mandatory for all facilities.
Discussion Points
- Review your facility’s policies and procedures for preventing and reporting false claims, and for conducting a comprehensive Triple Check Process to verify the accuracy of Medicare claims. Policies should be reviewed at least annually and updated as regulations evolve. Facilities may benefit from working with an external consultant to evaluate whether their current procedures reflect best practices and regulatory expectations.
- All staff should receive training upon hire and at least annually on the facility’s compliance and ethics policies—including what constitutes a false claim. Appropriate personnel should also receive targeted instruction on the Triple Check Process to ensure Medicare billing accuracy and sufficient supporting documentation before claims are submitted. Med-Net Academy offers the course Understanding and Using the Medicare Triple Check Process, which supports billing accuracy for skilled services, helps prevent false claims, and reduces the likelihood of adjusted or denied claims. The course also emphasizes aligning clinical documentation with financial data and ensuring residents receive the benefits to which they are entitled.
- Periodic audits should be conducted to confirm that staff understand compliance responsibilities and know how to report potential violations—whether to a supervisor, the compliance officer, or via the anonymous hotline. Monthly audits of the Triple Check Process should verify that it is being completed thoroughly and that any billing irregularities are corrected before submission. Engaging external reviewers can provide facilities with additional perspectives on potential risks or areas for improvement.
*This news alert has been prepared by Med-Net Concepts, Inc. for informational purposes only and is not intended to provide legal advice.*