Case Results

A Track Record Built
Case by Case.

The following results are anonymized to protect client confidentiality. They represent a cross-section of the enforcement actions we have defended — from program terminations to multimillion-dollar extrapolated audits to Departmental Appeals Board victories.

All case descriptions are anonymized. Past results do not guarantee future outcomes.

100+
DAB Victories
500+
Cases Defended
$100M+
In Demands Challenged
95%+
Favorable Outcomes
Program Termination

Home Health Agency — Western Region

At Stake

Full Medicare Program Termination

Outcome

Termination Reversed

CMS moved to terminate a home health agency's Medicare participation following an unannounced site visit citing alleged condition-of-participation deficiencies. We filed an immediate rebuttal, challenged the surveyor's findings with clinical documentation, and secured a full reversal at the State Supervisory level — keeping the agency operational without interruption.

Extrapolated Audit

Home Health Agency — Midwest

At Stake

$4.2M Overpayment Demand

Outcome

Reduced to $187K

A UPIC audit extrapolated a $4.2 million overpayment demand from a 100-claim sample. We challenged the statistical methodology, identified flaws in the universe construction, and successfully argued before an ALJ that the extrapolation was invalid. The final overpayment was reduced to $187,000 — a 96% reduction.

DAB Appeal

Hospice Organization — Mountain West

At Stake

$1.8M Overpayment Demand

Outcome

Full Reversal at DAB

Following an unsuccessful ALJ hearing, we pursued a Departmental Appeals Board appeal challenging the medical necessity determinations underlying a $1.8 million overpayment demand. The DAB reversed the ALJ decision in full, finding that the clinical documentation supported the home health care delivered and that the auditor's methodology was legally deficient.

Billing Privilege Revocation

DME Supplier — Northeast

At Stake

Revocation of Billing Privileges

Outcome

Reinstatement Secured

A durable medical equipment supplier faced revocation of Medicare billing privileges following a failed unannounced site visit. We identified procedural deficiencies in the MAC's process, filed a timely rebuttal with corrective documentation, and secured reinstatement within 45 days — well before the standard timeline.

Physician Defense

Independent Physician — Texas

At Stake

$2.1M Overpayment + OIG Referral

Outcome

Overpayment Eliminated, Referral Closed

A solo physician faced a $2.1 million overpayment demand and a referral to the OIG following a UPIC audit of evaluation and management billing. We provided a comprehensive clinical documentation defense, challenged the medical necessity denials at every level of appeal, and ultimately eliminated the overpayment demand entirely. The OIG referral was closed without further action.

Attorney Co-Counsel

Healthcare Law Firm — National

At Stake

Physician Pill Mill Case

Outcome

Case Resolved Favorably

A criminal defense attorney engaged us as expert consultants in a federal investigation involving a high-volume pain management practice. We applied advanced analytics to prescribing practices and forensic techniques that were instrumental in achieving an exceptionally favorable resolution for the client.

Extrapolated Audit

Home Health Provider — Los Angeles

At Stake

$890K Overpayment Demand

Outcome

Reduced to $41K

A RAC audit extrapolated an $890,000 overpayment demand against a Home Health provider based on alleged medical necessity deficiencies. We challenged the sample selection, the medical necessity criteria applied, and the extrapolation methodology. After ALJ hearing, the demand was reduced to $41,000 — a 95% reduction.

Program Termination

Skilled Nursing Facility — Mid-Atlantic

At Stake

Emergency Medicare Termination

Outcome

Termination Stayed, Operations Continued

A skilled nursing facility received an emergency termination notice with a 23-day effective date following a state survey. We immediately engaged, filed an emergency stay request, and worked with the facility's clinical team to develop a credible plan of correction. The termination was stayed and the facility retained its Medicare certification.

Extrapolated Audit

Home Health Agency — Southeast (Georgia)

At Stake

$3.1M Overpayment Demand

Outcome

Reduced to $214K

A ZPIC audit of a Georgia home health agency produced a $3.1 million extrapolated overpayment demand based on alleged homebound-status deficiencies across a 110-claim sample. We challenged the auditor's homebound determinations, identified errors in the universe construction, and demonstrated that the sample was not representative of the billing population. The ALJ reduced the demand to $214,000 — a 93% reduction.

Program Termination

Home Health Agency — Pacific Northwest (Oregon)

At Stake

Full Medicare Program Termination

Outcome

Termination Reversed at Reconsideration

Following an unannounced site visit, a State Survey Agency issued a termination notice to a home health agency citing alleged deficiencies in supervision of home health aides and clinical record documentation. We conducted a line-by-line review of the surveyor's findings, assembled a comprehensive clinical rebuttal, and demonstrated that the cited deficiencies were either corrected or factually unsupported. The termination was reversed in full.

Extrapolated Audit

Home Health Agency — Gulf Coast (Louisiana)

At Stake

$5.7M Overpayment Demand

Outcome

Reduced to $390K

A UPIC audit of a Louisiana home health agency extrapolated a $5.7 million overpayment demand from a 120-claim sample, citing widespread medical necessity failures. We retained a statistical expert, challenged the sampling frame and stratification methodology, and successfully argued before an ALJ that the extrapolation violated CMS statistical standards. The final demand was reduced to $390,000 — a 93% reduction.

Billing Privilege Revocation

Home Health Agency — Mid-South (Tennessee)

At Stake

Revocation of Medicare Billing Privileges

Outcome

Reinstatement Secured in 38 Days

A Tennessee home health agency received a revocation notice following a failed unannounced site visit that cited an inability to verify the agency's operational status. We identified that the site visit was conducted without proper advance coordination, documented the agency's active patient census and operational records, and filed a rebuttal that demonstrated the Surveyors findings were procedurally deficient. Billing privileges were reinstated within 38 days.

DAB Appeal

Home Health Agency — Great Plains (Kansas)

At Stake

$2.4M Overpayment Demand

Outcome

Full Reversal at DAB

After an adverse ALJ decision on a $2.4 million overpayment demand, we pursued a Departmental Appeals Board appeal challenging the ALJ's application of homebound-status criteria. The DAB reversed the ALJ decision in full, holding that the agency's clinical documentation met the applicable Medicare standards and that the auditor's methodology improperly applied a more restrictive standard than the regulations require.

Extrapolated Audit

Home Health Agency — Appalachian Region (West Virginia)

At Stake

$1.6M Overpayment Demand

Outcome

Reduced to $88K

A MAC post-payment review of a West Virginia home health agency produced a $1.6 million extrapolated demand based on alleged skilled-care necessity failures. We challenged the auditor's clinical determinations on a claim-by-claim basis, demonstrated that the treating physicians' orders and clinical notes supported the services rendered, and secured a 94% reduction at the ALJ level.

Program Termination

Home Health Agency — Desert Southwest (Arizona)

At Stake

Full Medicare Program Termination

Outcome

Termination Reversed, Agency Retained Certification

An Arizona home health agency received a termination notice following a state survey that cited deficiencies in its infection control and patient rights policies. We worked directly with the agency's clinical leadership to develop a credible plan of correction, filed a detailed rebuttal challenging the factual basis of several cited deficiencies, and secured a full reversal before the termination effective date.

Extrapolated Audit

Home Health Agency — Upper Midwest (Minnesota)

At Stake

$2.9M Overpayment Demand

Outcome

Reduced to $162K

A UPIC audit of a Minnesota home health agency extrapolated a $2.9 million overpayment demand, alleging that a significant portion of the agency's skilled nursing visits lacked medical necessity. We performed a comprehensive clinical documentation review, challenged the auditor's application of LCD criteria, and demonstrated systemic errors in the sample selection. The demand was reduced to $162,000 at the ALJ level — a 94% reduction.

Billing Privilege Revocation

Home Health Agency — Mid-Atlantic (Maryland)

At Stake

Revocation + 3-Year Re-enrollment Bar

Outcome

Revocation Overturned, Bar Lifted

A Maryland home health agency faced revocation of Medicare billing privileges and a three-year re-enrollment bar following allegations of improper billing patterns identified in a ZPIC review. We challenged both the factual basis for the revocation and the legal standard applied to impose the re-enrollment bar, demonstrating that the agency's billing practices were consistent with applicable Medicare guidelines. Both the revocation and the bar were overturned on appeal.

Extrapolated Audit

Home Health Agency — Rocky Mountain (Colorado)

At Stake

$780K Overpayment Demand

Outcome

Reduced to $34K

A post-payment review of a Colorado home health agency produced a $780,000 extrapolated overpayment demand based on a 40-claim sample. We identified that the sample size was statistically insufficient to support a valid extrapolation under CMS guidelines and successfully argued at the ALJ level that the extrapolation should be invalidated entirely. The final demand was reduced to $34,000 — a 96% reduction — based on the individually reviewed claims.

Program Termination

Home Health Agency — Deep South (Mississippi)

At Stake

Full Medicare Program Termination

Outcome

Termination Reversed, Operations Uninterrupted

A Mississippi home health agency received a 30-day termination notice after a state licensing survey cited three conditions of participation as out of compliance, primarily related to clinical supervision and patient assessment protocols. We compiled a comprehensive documentary record demonstrating the agency's compliance, directly challenged the survey findings, and secured a full reversal at the reconsideration level — with no interruption to patient care or Medicare billing.

DAB Appeal

Home Health Agency — New England (Massachusetts)

At Stake

$1.2M Overpayment Demand

Outcome

Full Reversal at DAB

A Massachusetts home health agency faced a $1.2 million overpayment demand following a post-payment review that denied skilled nursing visits across a two-year billing period, citing inadequate documentation of homebound status. After an adverse ALJ decision, we pursued a Departmental Appeals Board appeal and demonstrated that the ALJ applied an incorrect legal standard for homebound determination. The DAB reversed in full, restoring the entire amount at issue.

About These Results

All case results are anonymized to protect client confidentiality. Provider type, geographic region, and dollar amounts have been generalized where necessary. Past results do not guarantee future outcomes — every Medicare enforcement action is different, and results depend on the specific facts, documentation, and legal theories at issue.

What We Bring to Every Case
  • Former CMS employee — insider knowledge of how audits are built
  • Deep expertise in statistical extrapolation challenges
  • Representation through every level of the Medicare appeals process
  • Rapid response when termination or revocation notices arrive

Every enforcement action
has a defensible record.

The results above represent a cross-section of what methodical, analytical defense produces. Contact us for a confidential assessment of your situation.