Bill Amniotic Injections as Other Reimbursable Services

Health care providers cannot seek Medicare reimbursement for amniotic injections by billing them as other reimbursable services. This is another form of fraud that constitutes a violation of the False Claims Act, and mischaracterizing non-reimbursable services presents a high risk for allegations of intentional Medicare fraud.

• The False Claims Act establishes both civil and criminal penalties for violations. The federal health care fraud statute, 18 U.S.C. Section 1347, also imposes criminal penalties for fraudulently billing Medicare. Under the False Claims Act and the federal health care fraud statute, evidence of knowledge or intent is required in order to substantiate criminal charges. However, providers can face civil penalties under the False Claims Act for inadvertent billing mistakes—including mistakes that result from unfamiliarity with the pertinent Medicare billing rules and regulations. Civil penalties under the False Claims Act can include recoupments, treble damages, fines, other forms of financial liability, and Medicare exclusion. In criminal health care fraud cases, providers can face financial liability and federal imprisonment. Read more