Foreword: Unveiling the Shadows, Inspiring Change

The journey towards mental wellness and recovery from addiction is often walked by our most vulnerable citizens, individuals placing immense trust in the hands of those promising care and healing. It is with a heavy heart, therefore, that we confront the grim realities detailed in the following report – a landscape where that trust is too often betrayed through neglect, unethical practices, and outright illegal activity.

This document, “The Price of Neglect,” lays bare the significant enforcement actions, financial penalties, and facility closures levied against treatment centers across Ohio and the nation. It catalogues violations ranging from patient safety failures and conflicts of interest to healthcare fraud and illicit patient brokering. These are not mere statistics; they represent profound failures that can inflict devastating harm on individuals and families already facing immense challenges. Things Marion Watch and our national allies are committed to exposing and correcting nationwide. 

In the face of such systemic problems, the tireless commitment of organizations like Newsforce247 and Marion Watch Investigates, as well as their national allies like Jennifer Barton and others, becomes ever more critical. Investigative journalists and dedicated watchdog groups play an indispensable role, shining a light into the darkest corners of the industry, exposing misconduct, and demanding accountability where oversight may falter. Their resolve fuels the fight against the nationwide uptick in ethics violations and abuse within the addiction recovery and mental health sectors.

With Lives on the Line: Marion not Immune to Nationwide Pattern of Breaches, Standards, and Oversight: Ethical and Legal Complexities in Addiction Recovery

May the evidence presented herein serve not only as a record of transgressions but as a catalyst for action. It is offered in the spirit of supporting the vital work of advocates, regulators, and ethical providers striving to ensure that patient well-being, safety, and dignity are always placed above profit and convenience. The path to healing deserves integrity, and exposing the price of neglect is a crucial step towards achieving it.

MarionWatch, in collaboration with our national allies such as Jennifer Barton’s team and others unequivocally condemns these abhorrent acts, attributing them to individuals who are “oath breakers”. We stand firm in our support for the relentless pursuit and maximum legal prosecution of those responsible. We, the People, hold the power to demand unwavering transparency, accountability, and truth. This has tragically evolved into a nationwide crisis with a deadliness comparable to the very addiction it was initially intended to combat.

I. Introduction

A. Purpose and Scope

This report details significant enforcement actions, including facility closures and substantial financial penalties such as fines and settlements, levied against mental health facilities and addiction treatment centers in the state of Ohio and across the United States. The primary focus is on sanctions resulting from substantiated ethics complaints, encompassing issues like patient safety violations, neglect, and conflicts of interest, as well as documented illegal activities. These illegal activities notably include healthcare fraud, violations of federal and state anti-kickback statutes, illicit patient brokering schemes, and the operation of facilities without requisite licensure.

The objective of this report is to furnish a structured and evidence-based overview for professionals—including legal counsel, compliance officers, healthcare administrators, policy analysts, regulators, and investigative journalists—who require documented information concerning regulatory compliance failures and prevailing enforcement trends within the behavioral health sector. It aims to consolidate information from disparate sources into a coherent analysis of sanctions imposed on facilities within this critical area of healthcare.

B. Importance of Oversight in Behavioral Health

The population seeking mental health and addiction services represents a particularly vulnerable group, often facing significant personal challenges and relying heavily on the integrity and quality of the care provided. Compounding this vulnerability is the substantial investment of public funds, primarily through federal programs like Medicare and Medicaid, in financing these services. This confluence of patient vulnerability and significant public expenditure underscores the high potential for fraud, waste, and abuse within the sector. 

Consequently, robust regulatory oversight and stringent enforcement mechanisms are paramount. Effective oversight serves not only to safeguard patient safety and ensure the delivery of high-quality care but also to maintain the fiscal integrity of the healthcare system by preventing the diversion of taxpayer funds through fraudulent activities. Failure in oversight can lead to devastating consequences, including patient harm, exploitation, and significant financial losses to public programs.

C. Methodology and Structure

The findings presented in this report are derived from a comprehensive review of various information sources. The research methodology involved examining state-level databases and records pertaining to Ohio, including those maintained by the Ohio Department of Mental Health and Addiction Services (OhioMHAS), relevant state licensing boards (e.g., Counselor, Social Worker, Marriage and Family Therapist Board; State Medical Board; Board of Pharmacy), the Ohio Attorney General’s Office, and the Ohio Auditor of State. Federal databases, such as the Department of Health and Human Services Office of Inspector General (HHS-OIG) List of Excluded Individuals/Entities (LEIE) and Department of Justice (DOJ) settlement announcements, were also scrutinized. Additionally, public records, news archives, and reports from healthcare watchdog organizations were analyzed to capture instances of closures, fines, or significant sanctions related to ethical or legal violations nationwide.

This report is structured to provide a logical progression of information. Section II outlines the complex regulatory framework governing behavioral health facilities, detailing key federal and state laws and the agencies responsible for enforcement. Section III presents specific findings related to enforcement actions against facilities in Ohio, organized by county where feasible, and includes detailed case examples. Section IV broadens the scope to examine nationwide findings, highlighting major enforcement actions and prevalent themes across the United States. Section V offers an analysis synthesizing the Ohio and nationwide data, identifying common patterns of misconduct and discussing the effectiveness of enforcement measures. Finally, Section VI provides concluding remarks and high-level recommendations for various stakeholders.

II. Regulatory Landscape and Enforcement Mechanisms

The operation and oversight of mental health and addiction treatment facilities are governed by a complex web of federal and state laws and regulations, enforced by numerous agencies. Understanding this landscape is crucial for contextualizing the sanctions imposed on non-compliant facilities.

A. Key Federal Laws and Regulations

Several federal statutes form the bedrock of enforcement against fraud, abuse, and unethical conduct in healthcare, including the behavioral health sector.

• False Claims Act (FCA): This statute (31 U.S.C. §§ 3729–3733) is the government’s primary tool for combating fraud against federal programs. It imposes liability on individuals and entities that knowingly submit, or cause to be submitted, false or fraudulent claims for payment to the government. Key aspects include its qui tam provision, which allows private citizens (whistleblowers or relators) to file lawsuits on behalf of the government and share in any recovery. The FCA has been instrumental in recovering billions of dollars annually, with a significant portion stemming from the healthcare industry, including settlements involving behavioral health providers accused of billing for medically unnecessary services, services not rendered, or services tainted by kickbacks. Recent fiscal year recoveries consistently reach into the billions, underscoring the scale of fraud targeted by this act.
• Anti-Kickback Statute (AKS): Codified at 42 U.S.C. § 1320a-7b(b), the AKS is a criminal law that prohibits knowingly and willfully offering,cash or in kind, to induce or reward referrals of items or services payable by a federal healthcare program. The term “remuneration” is interpreted broadly to include anything of value. Violations relevant to treatment facilities often involve payments for patient referrals, offering inducements like free transportation or housing, waivers of copayments, or disguised payments through sham contracts for marketing or consulting services. The HHS-OIG has established “safe harbors” that define practices not subject to AKS enforcement, and it issues advisory opinions on specific proposed arrangements. Violations can lead to criminal penalties, civil monetary penalties, and exclusion from federal healthcare programs.
• Eliminating Kickbacks in Recovery Act (EKRA): Enacted in 2018 (18 U.S.C. § 220) as part of the SUPPORT Act to combat the opioid crisis, EKRA specifically targets patient brokering within the addiction treatment and recovery context. Unlike the AKS, EKRA applies to services covered by any payor, including private insurers, not just federal programs. It prohibits knowingly and willfully soliciting, receiving, paying, or offering any remuneration (directly or indirectly) in return for referring a patient or patronage to a recovery home, clinical treatment facility, or laboratory. This law has become a key tool in prosecuting schemes involving payments to “body brokers” who recruit individuals with substance use disorders for specific facilities, often involving inducements to the patients themselves. Penalties include significant fines and imprisonment.
• Stark Law (Physician Self-Referral Law): Found at 42 U.S.C. § 1395nn, the Stark Law prohibits physicians from making referrals for certain “designated health services” (DHS) payable by Medicare or Medicaid to an entity with which the physician (or an immediate family member) has a financial relationship (ownership/investment interest or compensation arrangement), unless a specific exception applies. While perhaps less frequently cited in facility-wide fraud cases compared to AKS or FCA, it can be relevant if facility ownership or compensation structures involve physicians making prohibited referrals for DHS. Violations can result in denial of payment, refunds, CMPs, and exclusion.
• Civil Monetary Penalties Law (CMPL): Located at 42 U.S.C. § 1320a-7a, the CMPL authorizes HHS-OIG to impose significant civil monetary penalties, assessments, and program exclusions for a wide range of fraudulent conduct. This includes submitting claims for items or services not provided, submitting claims for medically unnecessary services, violating the AKS, and, notably, employing or contracting with individuals or entities known to be excluded from federal healthcare programs. Penalties can be levied per violation, making them substantial in cases of systemic non-compliance.

B. Key State Laws and Regulations (Ohio Example)

States supplement federal oversight with their own laws, regulations, and licensing requirements. Ohio provides a relevant example:

• Ohio Ethics Law: Contained in Ohio Revised Code (ORC) Chapter 102 and related sections 2921.42 and 2921.43, this law establishes ethical standards and prohibits conflicts of interest for public officials and employees. While primarily aimed at government personnel, it could become relevant if state or county employees have improper financial relationships with treatment facilities receiving public funds. Violations are criminal offenses punishable by fines and potential jail time.
• Ohio Licensure Laws: Various state boards hold the authority to regulate professionals and, in some cases, facilities.

• The Ohio Counselor, Social Worker, and Marriage and Family Therapist (CSWMFT) Board regulates individual practitioners under ORC Chapter 4757. It can take disciplinary action (reprimand, suspension, revocation, restrictions) for violations including ethical breaches, criminal convictions, impairment due to substance abuse, practicing outside scope, fraud, and failure to report misconduct. However, the Board explicitly states it investigates individuals, not agencies. A public database lists disciplined licensees.
• The State Medical Board of Ohio licenses physicians and certain other practitioners. It investigates complaints and can impose discipline similar to the CSWMFT Board. Importantly, it does not license or regulate community mental health agencies; that falls under OhioMHAS. Its disciplinary information primarily concerns individual licensees.
• The Ohio Board of Pharmacy regulates pharmacists and the distribution of dangerous drugs under ORC Chapter 4729. Crucially, its authority extends to licensing and disciplining facilities involved in drug distribution, such as terminal distributors (which can include clinics or treatment programs). The Board can suspend, revoke, restrict, or fine these licensed distributors for violations including false statements, drug law violations, felony convictions, employing excluded individuals, or operating in a way that poses harm.
  

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• Ohio Medicaid Rules & Provider Agreements: Providers participating in Ohio Medicaid must adhere to program rules regarding medical necessity, documentation standards, billing procedures, and compliance with all applicable laws. Failure to comply can lead to audits by the Ohio Auditor of State resulting in findings of improper payments and demands for repayment , or investigation and prosecution for fraud by the Ohio Attorney General’s Medicaid Fraud Control Unit (MFCU).
• Ohio Patient Abuse and Neglect Law: ORC 109.86 grants the Ohio Attorney General authority to investigate and prosecute allegations of abuse and neglect of patients in healthcare facilities, including long-term care and potentially other settings where vulnerable individuals receive care.

C. Enforcement Agencies and Bodies

A multitude of agencies at the federal, state, and sometimes local levels are involved in the oversight and enforcement of regulations governing behavioral health facilities.

• Federal Agencies: The Department of Justice (DOJ), through its Civil and Criminal Divisions and numerous U.S. Attorney’s Offices nationwide, is the primary enforcer of federal laws like the FCA, AKS, and EKRA, often pursuing large civil settlements and criminal prosecutions. The Department of Health and Human Services Office of Inspector General (HHS-OIG) plays a critical role through audits, investigations, imposition of CMPs, negotiation of Corporate Integrity Agreements (CIAs), and maintaining the LEIE exclusion list. The Federal Bureau of Investigation (FBI) investigates healthcare fraud, often in partnership with DOJ and OIG. The Drug Enforcement Administration (DEA) investigates diversion of controlled substances, which can be relevant in addiction treatment settings. Collaborative efforts like the Health Care Fraud Prevention and Enforcement Action Team (HEAT) and various Strike Forces coordinate multi-agency actions.
• State Agencies (Ohio Example): The Ohio Attorney General’s Office, particularly its Medicaid Fraud Control Unit (MFCU), investigates and prosecutes Medicaid provider fraud and patient abuse/neglect. The Ohio Department of Mental Health and Addiction Services (OhioMHAS) handles the licensure and certification of mental health and addiction service providers , operates state psychiatric hospitals , and manages a complaint process. State Licensing Boards (CSWMFT, Medical, Pharmacy) oversee individual professionals and, in the case of the Pharmacy Board, certain facilities, with the power to impose disciplinary sanctions. The Ohio Department of Health (ODH) handles complaints regarding patient care and safety in licensed healthcare facilities and nursing homes. The Ohio Auditor of State conducts compliance audits of Medicaid providers. County Health Departments typically have a more limited role, focusing on environmental health and public nuisances rather than clinical practice or billing fraud within licensed facilities.
• Other Entities: Accrediting bodies like the Commission on Accreditation of Rehabilitation Facilities (CARF) and The Joint Commission set quality standards and can receive complaints, although their enforcement power differs from government agencies. Industry associations like the National Association of Addiction Treatment Providers (NAATP) may have ethics codes and complaint processes for member organizations. Watchdog groups and investigative media often play a crucial role in exposing misconduct and prompting official investigations.

D. Common Violations Leading to Sanctions

Analysis of enforcement actions reveals recurring categories of misconduct that trigger sanctions against behavioral health facilities:

• Healthcare Fraud: This broad category encompasses various schemes to illicitly obtain payment from healthcare programs. Common examples include billing for services never actually rendered to patients; billing for services that were not medically necessary given the patient’s condition; “upcoding,” or billing for a more expensive service than the one provided; falsifying patient records or documentation to support fraudulent claims; and billing for diagnostic tests (like urinalysis) that were excessive or unnecessary.
• Illegal Kickbacks and Patient Brokering: Particularly prevalent in the addiction treatment sector, these schemes involve paying or receiving remuneration for patient referrals in violation of the AKS and/or EKRA. This can manifest as direct payments to “body brokers” or marketers for each patient referred; offering illegal inducements to patients themselves (e.g., cash, free rent in sober homes, travel, drugs); disguising kickbacks through sham contracts for services like marketing or consulting; or engaging in complex lead-buying arrangements where call centers auction patients to the highest-bidding facility.
• Patient Safety, Abuse, and Neglect: Failures in the quality and safety of care can lead to severe sanctions. Common issues include inadequate staffing levels leading to inability to supervise patients properly or provide necessary care; failure to provide required therapy sessions or develop adequate treatment plans; improper use of physical or chemical restraints; failure to protect patients from harm, including assaults by other patients or staff, suicides, or elopements from the facility; unsanitary or unsafe facility conditions; and deliberate overmedication to manage difficult patients.
• Unlicensed Operation or Personnel: Operating a treatment facility without the required state license or certification is a fundamental violation. Additionally, employing individuals who lack the necessary professional licenses (e.g., therapists, nurses) or, critically, employing individuals who are listed on the HHS-OIG exclusion list, can result in significant penalties.
• Ethical Violations: While often addressed through individual licensing board actions, facility-level ethical breaches can occur. These might include systemic conflicts of interest, failure to protect patient confidentiality (though HIPAA violations are often investigated federally ), falsification of patient records or staff credentials, or violations of professional boundaries.

E. Types of Sanctions

Enforcement actions can result in a range of sanctions against facilities and associated individuals, varying in severity:

• Financial Penalties: These are common outcomes, especially in fraud and kickback cases resolved civilly. They include substantial fines, civil monetary penalties (CMPs) often levied per violation, orders of restitution to repay defrauded programs, forfeiture of assets derived from illegal activities, and large settlements negotiated with government agencies, frequently reaching millions or even hundreds of millions of dollars.
• Operational Sanctions: These directly impact a facility’s ability to operate. They can include temporary suspension of patient admissions , suspension or revocation of the facility’s operating license or certification by state agencies (OhioMHAS, ODH, Pharmacy Board) , placing the license on probation with specific conditions, or restricting the types of services the facility can offer. In severe cases, license revocation or insurmountable financial penalties can lead to permanent facility closure.
• Exclusion from Federal Healthcare Programs: HHS-OIG has the authority to exclude individuals and entities from participation in Medicare, Medicaid, TRICARE, and other federal healthcare programs. Excluded parties are listed on the LEIE. The primary effect is that no federal program payment can be made for any items or services furnished, ordered, or prescribed by the excluded party, either directly or indirectly. Exclusion can be mandatory for certain offenses (e.g., Medicare fraud conviction, patient abuse) or permissive for others (e.g., AKS violations, misdemeanor fraud, loss of license). Reinstatement requires a formal application process after the exclusion period.
• Enhanced Oversight: As part of settlements, particularly large ones involving corporate entities, HHS-OIG often requires the provider to enter into a Corporate Integrity Agreement (CIA). CIAs typically last five years and mandate specific compliance measures, employee training, reporting obligations, and reviews by an Independent Review Organization (IRO) to monitor claims and practices. Refusal to enter into a necessary CIA can lead to the provider being placed on OIG’s “Heightened Scrutiny” list.
• Criminal Penalties: For individuals involved in serious violations like large-scale fraud, intentional kickbacks, or patient abuse, criminal prosecution can lead to convictions resulting in imprisonment, substantial criminal fines, and forfeiture of assets.

The regulatory environment governing behavioral health facilities is characterized by significant complexity, with multiple layers of federal and state laws enforced by a variety of agencies often possessing overlapping jurisdictions. For instance, a facility engaging in a kickback scheme to generate medically unnecessary patient admissions could simultaneously violate the federal AKS, the federal FCA (by submitting claims tainted by kickbacks and for unnecessary services), potentially EKRA if addiction treatment is involved, and various state laws related to fraud and licensure. This single pattern of misconduct might trigger investigations and actions from the DOJ, HHS-OIG, the state Attorney General’s MFCU, and the relevant state licensing or facility oversight bodies. While this multi-layered approach aims for comprehensive enforcement, it necessitates careful coordination among agencies and presents considerable compliance challenges for providers navigating the intricate requirements.

Furthermore, analysis of enforcement actions reveals a pattern where the most substantial financial recoveries and resolutions of large-scale fraud involving facilities are predominantly driven by federal authorities, particularly the DOJ and HHS-OIG, leveraging the powerful provisions of the FCA and AKS. These major federal cases are frequently initiated based on information provided by whistleblowers under the FCA’s qui tam provisions. While state agencies, such as licensing boards and state Attorneys General, play crucial roles in addressing individual practitioner misconduct, patient safety issues, and fraud specific to state programs like Medicaid , the sheer scale of financial settlements in federal cases often dwarfs state-level recoveries. This suggests that federal enforcement mechanisms, particularly the FCA with its potential for treble damages and penalties, and the broad reach of the AKS, are the primary drivers in addressing systemic, high-dollar fraud and abuse within the behavioral health facility landscape nationwide.

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III. Findings: Ohio Treatment Facilities

A. Overview of Ohio Data Sources and Limitations

Identifying Ohio treatment facilities sanctioned for ethical or illegal activities requires consulting multiple sources, as no single, comprehensive public database exists for this specific purpose. Key sources and their limitations include:

• Ohio Department of Mental Health and Addiction Services (OhioMHAS): OhioMHAS is the primary state agency overseeing the mental health and addiction services system. It handles licensure and certification for providers and offers a mechanism for reporting complaints. However, OhioMHAS does not appear to maintain a publicly accessible database detailing disciplinary actions taken against facilities as a result of these complaints. Its public-facing information often emphasizes system development initiatives like Mobile Response and Stabilization Services (MRSS) and provider support resources , rather than enforcement actions.
• Ohio Licensing Boards: Boards regulating individual professionals (CSWMFT, Medical, Pharmacy) maintain records of disciplinary actions against their licensees. The CSWMFT provides a searchable database but explicitly states it does not investigate agencies, only individuals. The Medical Board’s disciplinary information and license lookup also primarily focus on individuals, and it does not license community mental health agencies. The Board of Pharmacy does have rules governing the discipline of licensed facilities (distributors), including suspension, revocation, and fines , making its records potentially relevant for certain types of treatment facilities handling medications. However, extracting facility-specific sanctions often requires navigating rules or actions primarily focused on individuals or specific license types.
• Ohio Attorney General (OAG) – Medicaid Fraud Control Unit (MFCU): This unit is a critical source for information on significant fraud cases involving facilities billing the Ohio Medicaid program. The OAG MFCU investigates and prosecutes provider fraud and patient abuse/neglect. Information on indictments, convictions, and settlements is often disseminated through official press releases.
• Ohio Auditor of State: The Auditor’s office conducts periodic compliance examinations of Medicaid providers, identifying improper payments due to non-compliance with billing regulations or documentation requirements. These audit findings, including recommended repayments, are made public and provide specific examples of financial sanctions against providers.
• County Health Departments: Local health departments in Ohio (e.g., Franklin County Public Health , Cuyahoga County Board of Health , Cleveland Department of Public Health ) primarily handle complaints related to environmental health, sanitation, food safety, and public health nuisances. Their jurisdiction generally does not extend to investigating complex healthcare fraud, clinical quality of care, or ethical violations within state-licensed treatment facilities. Broader facility complaints regarding patient care are typically directed to the Ohio Department of Health (ODH).
• News Archives and Public Records: Given the limitations of official databases, news reports and searches of public records (e.g., court filings related to settlements) are essential for identifying facility closures, details of violations, and sanctions not captured elsewhere.
• Overall Limitation: The primary challenge in fulfilling the user’s request for a county-by-county list is the fragmented nature of available data. There is no centralized repository in Ohio that aggregates all disciplinary actions, closures, and fines against treatment facilities specifically for ethical violations or illegal activities, organized geographically. Compiling such a list requires synthesizing information from the diverse federal and state sources listed above, with significant gaps likely remaining for less publicized or purely administrative actions. County-specific data, beyond cases reported by the OAG, Auditor, or major news outlets, is particularly difficult to obtain systematically.

B. Table 1: Selected Sanctioned Ohio Facilities by County

The following table provides illustrative examples of Ohio mental health and addiction treatment facilities or their parent companies that have faced significant sanctions, based on the available research. This list is not exhaustive due to the data limitations described above but highlights key cases identified through federal and state enforcement actions and audits.

Facility Name / Corporate Parent	County(ies)	Location(s)	Violation Type(s)	Action Taken	Date of Action/Report	Source/Notes
Oglethorpe Inc.	Guernsey, Ashtabula, Franklin	Cambridge, Ashtabula, Columbus	FCA Violations, Anti-Kickback Statute Violations (Free transportation as inducement), Medically Unnecessary Admissions	$10.25 Million Settlement, 5-Year Corporate Integrity Agreement (CIA) with HHS-OIG	Feb 2025	DOJ Settlement. Involved Cambridge Behavioral Hospital, Ridgeview Behavioral Hospital, The Woods at Parkside.
Braking Point Recovery Center	Mahoning, Franklin	Austintown, Whitehall	Healthcare Fraud Conspiracy (Medicaid), Billing for Services Not Provided/Unnecessary, Improper Coding, Kickbacks?	Criminal Convictions (Owners/Associates), Prison Sentences, >$24 Million Restitution, Asset Forfeiture	2019 (Indictment), 2020 (Sentencing)	DOJ/OAG News Release. Multi-agency investigation.
Janay Corbitt / Sham Agencies	Montgomery	Dayton Area	Felony Theft (Medicaid Fraud), Identity Fraud, Unlicensed Operation (Previously Barred Provider)	Criminal Conviction, 6-9 Years Prison Sentence, $1.5 Million Restitution	Apr 2025 (Sentencing)	OAG News Release. Operated two sham behavioral health agencies using stolen counselor identities.
Northeast Ohio Applied Health (NOAH) LLC	Summit	Akron? (Summit County)	Improper Medicaid Billing (Lack of Support/Documentation)	Audit Finding: $158,740 Improper Payments + $20,517 Interest = $179,257 Recommended Repayment	Apr 2023	Ohio Auditor of State Press Release.
Oriana House Inc.	Summit	Akron? (Summit County)	Improper Medicaid Billing (Lack of Support/Documentation)	Audit Finding: $85,036 Improper Payments + $12,755 Interest = $97,791 Recommended Repayment	Apr 2023	Ohio Auditor of State Press Release.
Community Assessment and Treatment Services Inc.	Cuyahoga	Cleveland? (Cuyahoga County)	Improper Medicaid Billing (Lack of Support/Documentation)	Audit Finding: $60,178 Improper Payments + $6,158 Interest = $66,336 Recommended Repayment	Apr 2023	Ohio Auditor of State Press Release.
Neurobehavioral Medicine Consultants P.C. Inc.	Belmont	St. Clairsville? (Belmont County)	Improper Medicaid Billing (Lack of Support/Documentation)	Audit Finding: $24,332 Improper Payments + $3,185 Interest = $27,517 Recommended Repayment	Apr 2023	Ohio Auditor of State Press Release.
Walnut Creek Nursing Center	Montgomery	Dayton	Employing Excluded Individual (LPN), Billing Federal Programs for Services by Excluded Individual	$243,000 Civil Monetary Penalty Settlement with HHS-OIG	Mar 2025 (Reported)	HHS-OIG Settlement Summary via News Report. Note: Nursing Center, included as it involves behavioral health aspects (LPN) and OIG exclusion enforcement.

C. Detailed Case Examples: Ohio

Several significant enforcement actions highlight the types of violations and consequences faced by Ohio behavioral health providers:

• Oglethorpe Inc. Facilities (Cambridge Behavioral Hospital, Ridgeview Behavioral Hospital, The Woods at Parkside): This 2025 settlement involved three Ohio facilities under the Florida-based Oglethorpe corporate umbrella, spanning Guernsey, Ashtabula, and Franklin counties. The $10.25 million resolution addressed allegations under the False Claims Act. The core violations included paying kickbacks, specifically providing free long-distance van transportation to induce patients to seek treatment, which violated the Anti-Kickback Statute. Additionally, the company was accused of submitting false claims to Medicare for inpatient psychiatric hospitalizations at Cambridge and Ridgeview that were deemed medically unnecessary. This case exemplifies enforcement against multi-site providers engaging in both prohibited inducement schemes (kickbacks) and billing for unnecessary care. The resolution included not only a substantial financial payment but also a demanding five-year Corporate Integrity Agreement (CIA) with HHS-OIG, mandating ongoing independent review of the facilities’ claims to federal healthcare programs, indicating a need for sustained corrective action and oversight.
• Braking Point Recovery Center: This case represents a large-scale criminal fraud conspiracy targeting the Ohio Medicaid program, operating out of facilities in Mahoning County (Austintown) and Franklin County (Whitehall). The owners, Ryan and Jennifer Sheridan, along with associates including physicians, were indicted in 2019 and subsequently sentenced in 2020 after pleading guilty to charges related to a scheme that billed Medicaid approximately $48 million, resulting in over $31 million in payments. The violations were extensive: billing for services never provided, billing for medically unnecessary services, improper coding to inflate reimbursements, lack of proper documentation, and distributing Suboxone (a medication for opioid use disorder) according to a standard protocol without individualized physician assessment of medical necessity. The consequences were severe, including lengthy prison sentences for the owners (Ryan Sheridan received 7.5 years), multi-million dollar restitution orders ($24.4 million for Ryan Sheridan), and forfeiture of significant assets, including luxury vehicles and real estate acquired with fraud proceeds. This case underscores the serious criminal liability associated with large-scale Medicaid fraud and highlights the coordinated efforts of federal agencies (DEA, HHS-OIG, FBI, IRS-CI) and the Ohio Attorney General’s MFCU in investigation and prosecution.
• Janay Corbitt / Sham Agencies (Dayton Area): This 2025 case involved an individual, Janay Corbitt, who had previously been convicted of theft and barred from participating in the Medicaid program. Despite this exclusion, she orchestrated a new fraud scheme, stealing multiple identities to establish and operate two fraudulent behavioral health counseling agencies in the Dayton area (Montgomery County). She further stole the identities of licensed counselors, using their credentials to bill Ohio Medicaid $1.5 million for counseling services that were never actually provided. After fleeing the state, she was apprehended and ultimately pleaded guilty to felony theft and identity fraud, receiving a prison sentence of six to nine years and an order to pay $1.5 million in restitution. This case demonstrates the audacity of some fraud perpetrators, the exploitation of stolen identities, and the critical role of the state MFCU in uncovering and prosecuting such schemes, even when they involve creating entirely fictitious operations.
• Ohio Auditor of State Medicaid Compliance Audits: Distinct from fraud investigations, routine compliance audits conducted by the Ohio Auditor of State regularly identify significant amounts of improper Medicaid payments resulting from non-compliance with program rules. A 2023 press release highlighted findings from audits of four mental health and addiction service providers across Summit, Cuyahoga, and Belmont counties. Northeast Ohio Applied Health (NOAH) LLC, Oriana House Inc., Community Assessment and Treatment Services Inc., and Neurobehavioral Medicine Consultants P.C. Inc. were collectively found to have received over $328,000 in improper payments (plus interest, totaling nearly $371,000 recommended for repayment) due to issues like lacking required supporting documentation for billed services or failing to adhere to other Medicaid regulations. These audits illustrate a different facet of enforcement – administrative compliance checks that uncover substantial billing errors and non-compliance, leading to financial recoupment by the state, even absent proof of intentional fraud.
• Walnut Creek Nursing Center (Dayton): This case, reported in March 2025, highlights the specific consequences of employing individuals excluded from federal healthcare programs. Walnut Creek Nursing Center, located in Montgomery County, agreed to pay $243,000 in a settlement with HHS-OIG. The penalty stemmed from the facility employing a Licensed Practical Nurse (LPN) who was on the HHS-OIG List of Excluded Individuals and Entities (LEIE) and subsequently billing federal healthcare programs (like Medicare or Medicaid) for items or services provided by that excluded nurse. This underscores the strict liability nature of employing excluded personnel and the significant financial penalties facilities face for failing to conduct regular and thorough checks against the OIG exclusion list.

The enforcement landscape within Ohio clearly involves a collaborative, yet sometimes fragmented, approach. Major fraud cases, particularly those with large financial implications or involving interstate elements, often see federal agencies like the DOJ and HHS-OIG taking the lead, utilizing statutes like the FCA and AKS, as seen in the Oglethorpe settlement. Simultaneously, the Ohio Attorney General’s MFCU actively investigates and prosecutes Medicaid fraud and patient abuse, leading to significant state-level criminal cases like Braking Point and Corbitt. State administrative bodies also play crucial roles: licensing boards address professional standards and conduct, with the Pharmacy Board having direct authority over certain facility types , while the State Auditor ensures compliance with Medicaid billing rules through routine audits. This demonstrates a multi-pronged strategy targeting different aspects of misconduct, from large criminal conspiracies to administrative billing errors.

However, constructing a truly comprehensive, county-by-county list of all sanctioned facilities, as requested by the user query, presents considerable challenges due to the way data is collected and disseminated. As noted previously, state-level databases maintained by licensing boards are often focused on individual practitioners rather than facilities , and agencies like OhioMHAS lack publicly available lists of facility disciplinary actions. County health departments generally lack jurisdiction over these types of violations. Consequently, identifying sanctioned facilities relies heavily on synthesizing information from publicly announced federal settlements , state AG or Auditor press releases , OIG enforcement summaries , and news media coverage. This approach effectively captures major enforcement actions but likely misses smaller fines, administrative sanctions imposed solely by licensing boards (particularly if framed around individual conduct within a facility), or facility closures resulting purely from financial insolvency rather than direct regulatory action, making a fully exhaustive county-level inventory difficult to achieve. The available data provides a strong picture of major enforcement trends but may underrepresent the total number of facilities facing less severe or less publicized sanctions across all 88 Ohio counties.

IV. Findings: Nationwide Treatment Facilities

A. Overview of Federal Oversight and Nationwide Data Sources

Oversight of behavioral health facilities nationwide involves a combination of federal agencies, state-level bodies, and non-governmental entities. Key data sources for identifying sanctioned facilities across the U.S. include:

• HHS-OIG Exclusions Database (LEIE): This is a critical federal resource, providing a public list of individuals and entities barred from participating in Medicare, Medicaid, TRICARE, and other federal healthcare programs due to convictions for program-related fraud, patient abuse, licensing board actions, or other specified reasons. The database is searchable online by individual or entity name. Healthcare providers are obligated to screen potential and current employees and contractors against this list to avoid substantial Civil Monetary Penalties (CMPs) for employing or contracting with excluded parties. While reinstatement is possible, it requires a formal application process after the exclusion term. Some states also maintain their own exclusion lists.
• Department of Justice (DOJ) Settlements: DOJ press releases and case filings are primary sources for information on major civil settlements and criminal prosecutions involving healthcare fraud and kickbacks nationwide. These often involve violations of the FCA, AKS, and EKRA, frequently resulting from qui tam (whistleblower) lawsuits. DOJ’s annual summaries of FCA recoveries consistently show billions of dollars recouped each year, with the healthcare sector accounting for the largest share.
• National Practitioner Data Bank (NPDB): This confidential federal database collects reports on medical malpractice payments and certain adverse actions (related to licensure, clinical privileges, professional society membership) taken against individual healthcare practitioners. While it primarily tracks individuals, patterns of reports against practitioners at a specific facility could indicate underlying systemic issues. Access is restricted to authorized entities like hospitals and licensing boards, not the general public.
• State Licensing Boards Nationwide: Each state has its own set of licensing boards responsible for regulating various healthcare professionals (physicians, nurses, therapists, psychologists, social workers, etc.). The accessibility and content of public disciplinary records vary significantly by state and profession. Some boards may have direct authority to discipline facilities (e.g., state pharmacy boards ), while others focus solely on individuals. Resources like Nursys aggregate licensure and disciplinary information for nurses across participating states.
• Centers for Medicare & Medicaid Services (CMS) Enforcement: CMS, the federal agency administering Medicare and overseeing Medicaid, can take enforcement actions against facilities for non-compliance with program requirements. This may include imposing CMPs for violations of specific regulations like the Emergency Medical Treatment and Labor Act (EMTALA) or hospital price transparency rules , or taking actions against certified providers like Home Health Agencies (HHAs). While significant, CMS enforcement actions may not capture the full spectrum of fraud and ethical violations pursued by DOJ or OIG.
• Watchdogs, News Media, and Research Reports: Non-governmental sources are invaluable for identifying emerging trends, systemic problems, specific instances of patient abuse or neglect, facility closures, and details of fraud schemes that may not yet be reflected in official enforcement databases or are slow to be reported publicly. Reports from organizations like the Government Accountability Office (GAO) and in-depth investigative journalism often provide critical context and uncover issues before or alongside official actions.

B. Table 2: Selected Nationwide Sanctioned Facilities/Settlements

This table presents significant examples of enforcement actions against behavioral health facilities or their corporate parents across various states, illustrating the national scope and common types of violations and sanctions. It is intended to be illustrative rather than exhaustive.

Facility/Corporate Name	State(s) Involved	Violation Type(s)	Action Taken	Date of Action/Report	Source/Notes
Universal Health Services, Inc. (UHS) & UHS of Delaware, Inc.	Nationwide (Settlement involved multiple states incl. OH, GA, MI, PA, etc.)	FCA Violations, Medically Unnecessary Services, Improper Admissions/Discharges, Excessive Lengths of Stay, Inadequate Staffing/Care, Improper Restraints, Billing for Services Not Rendered	$117 Million Civil Settlement (Federal & States), 5-Year Corporate Integrity Agreement (CIA) with OIG	Jul 2020	DOJ/OIG Press Releases. Resolved 18 qui tam lawsuits. Ohio was part of NAMFCU negotiating team.
Turning Point Care Center, LLC (UHS Facility)	Georgia	Anti-Kickback Statute Violations (Free/Discounted Transportation as Inducement)	Part of $122 Million Global UHS Settlement ($5M allocated to this)	Jul 2020	DOJ Press Release.
Acadia Healthcare Company, Inc.	Nationwide (Settlement involved FL, GA, MI, NV; other issues reported IL, TN, MO, NY, etc.)	FCA Violations, Medically Unnecessary Services, Improper Admissions/Discharges, Excessive Lengths of Stay, Inadequate Staffing/Care leading to harm (assaults, suicides), Failure to Provide Active Treatment	$19.85 Million Civil Settlement (Federal & States), Ongoing Federal Investigations, $400M+ Settlements for Abuse at a Closed Facility	Sep 2024/Feb 2025 (Settlement); Ongoing Scrutiny	DOJ/State AG Press Releases , News Reports. Resolved 2 qui tam lawsuits.
Oglethorpe Inc.	Ohio (See Table 1), Florida (HQ)	FCA Violations, Anti-Kickback Statute Violations (Free Transportation), Medically Unnecessary Admissions	$10.25 Million Settlement, 5-Year CIA with OIG	Feb 2025	DOJ Press Release.
Compass Detox LLC & WAR Network Inc. (Operators: Markovich Brothers)	Florida	Healthcare Fraud Conspiracy, Wire Fraud, Kickbacks (Patient Brokering, Lab Kickbacks), Medically Unnecessary Services (Testing), Services Not Provided (Therapy), Money Laundering, Bank Fraud (PPP Loans)	Criminal Convictions, Prison Sentences (188 months & 97 months), Sentencing Pending for others	Nov 2021 (Conviction), Apr 2022 (Sentencing)	DOJ Press Releases. $112 Million fraud scheme. Part of DOJ Sober Homes Initiative.
Good Decisions Sober Living (Medical Director: Mark G. Agresti; Owner: Kenneth Bailynson)	Florida	Healthcare Fraud Conspiracy, Kickbacks (Patient Recruitment for Unnecessary Testing)	Criminal Convictions, Prison Sentences (Agresti: 100 months; Bailynson: 72 months), $31.3 Million Restitution	Jun 2022 (Sentencing)	DOL News Release. $106 Million in false claims submitted.
Kenneth Chatman / Reflections Treatment Center, Journey to Recovery LLC, etc.	Florida	Healthcare Fraud Conspiracy, Money Laundering, Sex Trafficking (Forcing patients into prostitution)	Criminal Conviction, 27.5 Years Prison Sentence, Co-conspirators also sentenced	2017 (Sentencing)	FBI News Story. Estimated $24 Million fraud. Involved excessive/fraudulent testing, kickbacks, patient abuse.
Arizona Sober Living Home Scheme Providers	Arizona (Targeting Native Americans from multiple states)	Medicaid Fraud, Patient Brokering, Unlicensed Operations, Potential Neglect/Harm	>300 Providers had payments suspended/licenses terminated by AHCCCS, Limited Criminal Prosecutions/Restitution, State System Overhaul	May 2023 onwards	AHCCCS Website , News Reports , OIG Alert.
Casa Bella International Inc. & Nationwide Recovery (Operators: Lomonaco, Mohases, Williams, Reeves, Frageau)	California	Insurance Fraud, Money Laundering, Patient Brokering (Recruiting out-of-state patients, falsifying applications, kickbacks)	Criminal Charges Filed, Arrests Made	Jan 2020	CA Dept. of Insurance Press Release. Alleged $3.2 Million scheme.
Multi-State Patient Brokering Scheme (Operators: Dickau, Mohammad, Welsh, Devlin, Costas)	California, New Jersey, Maryland, others	EKRA Violations (Kickbacks for Referrals), Healthcare Fraud Conspiracy (Bribing patients to enroll)	Guilty Pleas (Conspiracy), Sentencing Pending/Occurred	Sep 2020, Nov 2020 (Pleas)	DOJ Press Releases. Involved marketing company brokering patients to facilities nationwide.
Action Recovery Group	Utah	Employing Excluded Individual	$73,457 Civil Monetary Penalty Settlement with HHS-OIG	Mar 2025 (Reported)	HHS-OIG Settlement Summary via News Report.
Intrepid U.S.A. Inc.	Nationwide (Home Health & Hospice)	FCA Violations (Billing for ineligible/improperly certified home health patients, services not reasonable/necessary; billing for ineligible hospice patients)	$3.85 Million Settlement	Feb 2025	DOJ Press Release. Resolved 2 qui tam lawsuits.
Community Health Network, Inc.	Indiana	Stark Law Violations, Anti-Kickback Statute Violations (Paying physicians above FMV, referral-based bonuses)	$345 Million Settlement	Jan 2024 (Reported in FY24 Summary)	DOJ FY24 Summary.
Oak Street Health (CVS Health subsidiary)	Nationwide (Medicare Advantage Clinics)	Anti-Kickback Statute Violations (Payments to insurance agents for patient recruitment)	$60 Million Settlement	Jan 2024 (Reported in FY24 Summary)	DOJ FY24 Summary , News Report.

C. Key Themes and Major Enforcement Actions Nationwide

Analysis of enforcement actions across the United States reveals several dominant themes and significant cases that illustrate the challenges within the behavioral health sector.

• Large-Scale Healthcare Fraud and Medically Unnecessary Services: A recurring pattern involves large healthcare corporations operating multiple facilities engaging in systematic schemes to defraud federal healthcare programs, primarily Medicare and Medicaid. These schemes often center on billing for services that are not medically necessary, admitting patients who do not meet criteria for the level of care provided, keeping patients longer than required, or billing for services not rendered at all.

• The Universal Health Services (UHS) case stands as a landmark example. In 2020, UHS, one of the nation’s largest healthcare providers, agreed to a $122 million global settlement ($117 million from UHS Inc. and subsidiaries, $5 million from its Turning Point facility) to resolve extensive False Claims Act allegations. The allegations spanned numerous inpatient behavioral health facilities nationwide over more than a decade (2006-2018) and included admitting ineligible federal beneficiaries, failing to discharge patients appropriately leading to excessive lengths of stay, billing for services not rendered, failing to provide adequate staffing, training, and supervision (resulting in patient harm), improper use of restraints and seclusion, and failure to provide required therapy and treatment planning. The settlement resolved 18 whistleblower lawsuits and mandated a five-year CIA with HHS-OIG, requiring stringent independent monitoring of UHS’s patient care practices and claims. The involvement of the National Association of Medicaid Fraud Control Units (NAMFCU), including representatives from Ohio, underscores the multi-state impact and coordinated response.
• Similarly, Acadia Healthcare Company, another major behavioral health provider, faced significant scrutiny. In late 2024/early 2025, Acadia agreed to pay $19.85 million to settle federal and state (Florida, Georgia, Michigan, Nevada) claims under the FCA and related statutes. The allegations, covering 2014-2017, mirrored many seen in the UHS case: billing for medically unnecessary inpatient services, improper admissions and discharges leading to excessive stays, and inadequate staffing, training, or supervision resulting in patient harm such as assaults, elopements, and suicides. Following this settlement, Acadia disclosed further federal investigations into its practices and faced additional scrutiny stemming from media reports and massive civil settlements (over $400 million) related to allegations of abuse at a specific, now-closed facility.

• Illegal Kickbacks and Patient Brokering: This remains a pervasive issue, particularly concentrated in the addiction treatment industry and associated sober living homes. These schemes violate the AKS and, since 2018, EKRA, which specifically targets such practices regardless of payor type. Common tactics include paying “body brokers” or marketers for patient referrals, offering direct inducements (cash, travel, free rent, drugs) to vulnerable individuals seeking treatment, using sham contracts to disguise payments, and engaging in sophisticated lead-buying operations where call centers effectively auction patients to facilities.

• The phenomenon known as the “Florida Shuffle” exemplifies this problem. Numerous investigations and prosecutions have targeted fraudulent rehabilitation centers and sober homes, primarily in South Florida, that recruited patients (often insured individuals from other states), paid kickbacks for referrals, housed them in often unregulated sober homes, and then submitted massive bills to insurance companies (initially often exploiting Affordable Care Act marketplace plans) for medically unnecessary services, particularly excessive and frequent urinalysis testing, while providing substandard or even harmful “treatment”. The DOJ established a dedicated Sober Homes Initiative to combat these schemes , and numerous individuals involved, including facility owners and medical directors, have received lengthy prison sentences and orders for tens of millions in restitution.
• A similar large-scale fraud emerged in Arizona, specifically targeting vulnerable Native American populations. Unscrupulous providers allegedly used patient brokers and unlicensed sober living homes to recruit individuals, often transporting them far from their communities, and then billed the state’s Medicaid program (AHCCCS) for fraudulent or non-existent behavioral health services. This led to widespread harm, including displacement and deaths, prompting tribes to declare health emergencies. The state response involved suspending payments to hundreds of providers, implementing emergency rules, contracting for forensic audits, and initiating a system overhaul, although criminal prosecutions and restitution have been criticized as insufficient given the scale of the harm.
• California has also seen significant patient brokering enforcement, including criminal charges against operators of facilities like Casa Bella International for allegedly trafficking out-of-state patients and using fraudulent insurance applications and money laundering to facilitate a $3.2 million scheme. Federal prosecutors have utilized EKRA to convict individuals involved in paying millions in kickbacks for patient referrals to addiction treatment facilities. Multi-state brokering rings, involving recruiters in states like New Jersey and Maryland bribing patients to travel to facilities in California and elsewhere, have also been prosecuted.
• Beyond addiction treatment, kickback schemes leading to large settlements occur across healthcare, including cases involving nationwide therapy providers paying for nursing home referrals , pharmaceutical distributors providing free inventory systems as inducements , and healthcare systems paying physicians excessive compensation tied to referrals in violation of Stark Law and AKS.
  

Other Notable High Profile Cases:

• Dr. Randy Rosen (California): A significant California case concluded in August 2022 involved Dr. Randy Rosen, a Beverly Hills surgeon, sentenced to 10 years in state prison for a nearly $38 million insurance fraud scheme targeting the state’s workers’ compensation system. This scheme involved recruiting patients from sober living homes via “body brokers” for medically unnecessary surgeries (Naltrexone implants, cortisone shots) and tests. Rosen’s girlfriend, Liza Visamanos, owned the lab (Lotus Laboratories) used for unnecessary drug testing, representing a conflict of interest under California law. The total fraudulent billing was estimated at $600 million, with about $50 million paid out. Rosen was ordered to pay $9.1 million in restitution and forfeit over $22 million in liens. This case represents one of the largest individual provider fraud sentences in California’s workers’ compensation system history.

• Scott Raffa / Sober Partners (California): In April 2024, Scott Raffa, operator of Sober Partners addiction treatment facilities in Orange County, California, was indicted on federal charges for allegedly paying approximately $174,600 in illegal kickbacks to “body brokers” between April 2020 and October 2021. The indictment includes 12 counts of illegal remunerations for referrals. Raffa allegedly used sham contracts to conceal the kickbacks, which were reportedly calculated based on expected insurance revenue and duration of patient stay, specifically requiring a minimum 21-day stay for payment. This case falls under the DOJ’s ongoing efforts to combat fraud in the sober living industry. Raffa’s trial was anticipated for early 2025.

• Darius Moore (California/North Carolina): Representing the role of individual “body brokers,” Darius Moore, formerly of Orange County, California, was sentenced in April 2025 to 84 months (7 years) in federal prison. Moore pleaded guilty in November 2021 to receiving nearly $500,000 in illegal kickbacks between February and December 2020 from corrupt sober living facilities for brokering patients. Moore knew the facilities billed private insurance for the referred patients’ treatment and paid him a share. His sentence also covered a subsequent federal conviction for firearms trafficking, committed while on bond for the patient brokering charges.

• Michael Lohan (Florida): Patient brokering enforcement also extends to individuals acting as recruiters. Michael Lohan (father of actress Lindsay Lohan) pleaded guilty in 2022 in Palm Beach, Florida, to five counts of patient brokering. He received four years of probation for illegally accepting kickbacks (at least $25,000) for referring individuals struggling with addiction to a specific rehabilitation facility. In April 2025, Lohan was sentenced to nine months in jail for violating this probation following an unrelated arrest.

• Daniel Kaine & Jason Gadreault (Florida): Underscoring the illicit ties between recruiters and labs, Daniel Martin Kaine was arrested in Boca Raton, Florida, in July 2020, charged with six counts of patient brokering. He allegedly received at least $70,000 in kickbacks between April and August 2017 from recruiter Jason Gadreault. Gadreault, arrested earlier (approx. Feb/Mar 2019), reportedly received over $700,000 (specifically $772,911 cited) from Genesis Diagnostics (a Pennsylvania lab) for steering urine tests its way, often from sober homes like Your Life Recovery where Kaine acted as a contact. Gadreault allegedly paid Kaine a portion ($125 out of $150 received per test) for tests originating from Kaine’s facility contacts. This highlights the common scheme of kickbacks driving unnecessary, high-reimbursement laboratory testing.

• Bieda Family / Academy Health Solutions (Florida): Family-run operations have also been implicated in fraud schemes. In November 2021, Mimi Bieda and her sons, Levi and David Bieda, operators of Academy Health Solutions in Lake Park, Florida, were arrested on patient brokering and money laundering charges. They were accused of receiving over $2 million in kickbacks between 2017 and 2018 for patient referrals, primarily involving steering urine tests to labs in which they held financial interests (including Jayde Laboratories and District Diagnostics), thereby violating self-referral prohibitions and engaging in kickback schemes. Reports in late 2021 indicated the family members received 10-year probation terms after pleading to patient brokering charges.

• Patient Safety, Abuse, and Neglect: Failures in providing safe and adequate care represent another critical area of enforcement and concern, often intertwined with financial misconduct. Inadequate staffing, insufficient training or supervision, and a focus on profit over patient well-being in some for-profit facilities are frequently cited as contributing factors. These failures can manifest in tragic ways, including physical and sexual abuse, preventable suicides or overdoses, patient elopements leading to harm, failure to provide a safe environment, improper use of restraints or sedation, and general neglect.

• Investigative reports on California psychiatric hospitals, particularly for-profit facilities, have documented alarming patterns of safety violations, including assaults, sexual abuse, and deaths, often met with weak state regulatory responses characterized by minimal fines and a reluctance to halt admissions despite repeated failures. Facilities like Santa Rosa Behavioral were cited for failing to properly investigate and report abuse allegations. Separately, Los Angeles County faced investigation for alleged abuse and neglect related to its practice of holding individuals on mental health conservatorships in jail or locked psychiatric units long past necessity due to a lack of community placements.
• The case of Sovereign Health in California provides a stark example. Following an FBI raid, the now-defunct company faced multiple lawsuits, including an $11 million settlement for the wrongful death of a patient who died by suicide at one of its facilities. Allegations included false marketing promises about the level of care, inadequate supervision by untrained staff, and operating in a “shady” manner. A jury later found Sovereign and its CEO liable for nearly $45 million in fraud in a case brought by an insurer, and a federal investigation remains ongoing.
• Sequel Youth and Family Services has also been highlighted as an example of systemic problems in for-profit behavioral healthcare, facing scrutiny across multiple states for unsafe conditions, understaffing, and allegations of patient abuse, including sexual abuse.

• Role of Corporate Integrity Agreements (CIAs): CIAs have become a standard component of large civil settlements between HHS-OIG and healthcare providers, particularly corporate entities operating multiple facilities. These agreements impose mandatory compliance obligations for a set period (typically five years), often requiring the retention of an Independent Review Organization (IRO) to conduct audits and reviews, enhanced training programs, specific reporting requirements to OIG, and other measures designed to prevent recurrence of the misconduct that led to the settlement. They represent a significant tool for OIG to exert ongoing oversight and compel systemic changes within organizations that have demonstrated compliance failures. A provider’s refusal to enter into a CIA when deemed necessary by OIG can result in the provider being placed on a public “Heightened Scrutiny” list, signaling ongoing compliance concerns.

The breadth and depth of these nationwide enforcement actions, particularly the multi-hundred-million-dollar settlements involving major corporate providers like UHS and Acadia, alongside targeted initiatives like the DOJ’s Sober Homes Initiative, strongly suggest that healthcare fraud, illegal kickbacks, and associated quality-of-care failures are not merely isolated incidents but represent systemic challenges within certain segments of the behavioral health industry. The recurrence of similar violation patterns—such as billing for medically unnecessary services or engaging in patient brokering—across different states and providers points to widespread vulnerabilities and, in some cases, deliberate strategies to exploit healthcare programs for financial gain. The national scale is further evidenced by the consistent recovery of billions of dollars annually through FCA enforcement, with healthcare fraud constituting the largest portion.

Furthermore, a critical connection exists between facilities engaging in large-scale financial fraud and those exhibiting deficiencies in patient care and safety. The drive to maximize revenue through fraudulent billing practices, such as admitting ineligible patients, extending stays unnecessarily, or billing for phantom services, often correlates with operational decisions that compromise care quality. This can include reducing staffing levels below safe minimums, hiring undertrained or unlicensed personnel, failing to provide adequate supervision, neglecting essential therapeutic services, or creating environments where patient harm is more likely to occur. The major settlements involving UHS and Acadia explicitly linked allegations of improper billing with failures in staffing, training, and supervision that resulted in documented patient harm, including assaults and suicides. Similarly, the Florida sober home cases revealed how schemes focused on kickbacks and fraudulent testing often involved facilities providing little to no effective treatment and sometimes even enabling continued substance use. This pattern suggests that financial integrity and patient safety are often deeply intertwined, and failures in one area frequently signal risks in the other.

These fraudulent schemes often demonstrate a pattern of exploiting specific vulnerabilities inherent in the patient population and the healthcare system itself. Addiction, mental illness, homelessness, lack of stable housing, and reliance on public insurance programs create opportunities for unscrupulous operators. Patient brokering schemes explicitly leverage addiction by offering cash, drugs, or housing as inducements for enrollment. The Arizona sober home fraud specifically targeted Native Americans, exploiting cultural factors and geographic isolation alongside addiction and poverty. The initial phases of the “Florida Shuffle” capitalized on the expanded insurance coverage under the ACA, with brokers enrolling out-of-state individuals in plans using false addresses to facilitate billing for unnecessary services. This targeted exploitation underscores the predatory nature of many healthcare fraud schemes within the behavioral health sector.

V. Analysis and Insights

A. Synthesis of Ohio and Nationwide Findings

Comparing the enforcement actions documented in Ohio with those observed nationwide reveals significant parallels. Ohio facilities have been subject to major enforcement actions reflecting the dominant national trends. The Oglethorpe settlement in Ohio mirrors nationwide cases like UHS and Acadia, involving allegations of kickbacks (improper transportation) and medically unnecessary services leading to large federal settlements and CIAs. The Braking Point Recovery Center case exemplifies the large-scale Medicaid fraud seen in addiction treatment settings nationally, involving billing for non-rendered or unnecessary services and improper medication protocols, resulting in criminal convictions and substantial restitution, similar to schemes prosecuted under the DOJ’s Sober Homes Initiative in Florida and elsewhere. The case of Janay Corbitt creating sham agencies highlights the lengths to which individuals will go to defraud Medicaid, a pattern seen nationally. Furthermore, the Ohio Auditor’s findings of improper Medicaid payments due to documentation failures reflect routine compliance issues encountered across states , while the OIG penalty against Walnut Creek Nursing Center for employing an excluded individual underscores a compliance obligation and enforcement risk faced by providers everywhere. The enforcement mechanisms employed in Ohio—federal FCA/AKS litigation, state MFCU prosecutions, OIG exclusions and CMPs, state licensing board actions, and state audits—are consistent with the multi-layered enforcement approach utilized nationwide.

B. Common Patterns of Misconduct

Across both Ohio and the nation, the most prominent patterns of misconduct leading to sanctions against behavioral health facilities converge around three interrelated themes:

1. Profit-Driven Fraud: Systematically defrauding government and private payors through schemes like billing for medically unnecessary services, billing for services never rendered, upcoding, falsifying documentation, and conducting excessive testing.
2. Kickback-Fueled Patient Acquisition: Utilizing illegal remuneration (kickbacks, bribes, inducements) to secure patient referrals, particularly prevalent in the competitive addiction treatment market. This includes patient brokering, payments to marketers, sham contracts, and providing prohibited benefits to patients.
3. Compromised Patient Care and Safety: Financial pressures or a deliberate focus on profit over care leading to inadequate staffing, poor training, lack of supervision, failure to provide necessary therapeutic services, neglect, abuse, and unsafe conditions.

The involvement of large, multi-facility corporate chains (e.g., UHS, Acadia, Oglethorpe) in some of the most significant settlements suggests that corporate structures and pressures can sometimes facilitate or fail to prevent widespread misconduct across numerous locations.

C. Scale of Financial Impact

The financial consequences of fraud and abuse in the behavioral health sector are substantial. Nationwide, DOJ recoveries under the False Claims Act consistently reach billions of dollars annually, with the healthcare industry, including behavioral health, accounting for the largest share. Individual settlements with large providers like UHS ($122M) and Community Health Network ($345M, Stark/AKS case) demonstrate the massive sums involved. In Ohio, cases like Oglethorpe ($10.25M settlement) and Braking Point ($24M+ restitution) also represent significant financial penalties. 

These figures primarily represent direct losses recovered for federal programs like Medicare and Medicaid and state Medicaid programs, funded by taxpayers. However, the true cost extends beyond these recovered amounts, encompassing the costs of investigations and prosecutions, the financial and emotional harm to patients who received unnecessary or substandard care, the potential increase in insurance premiums due to fraud, and the erosion of public trust in the behavioral healthcare system.

D. Effectiveness of Enforcement Actions

The effectiveness of current enforcement mechanisms presents a mixed picture.

• Impact of Sanctions: Large financial settlements and fines aim to recoup losses and deter future misconduct. However, for large corporations, even multi-million dollar settlements might be perceived as a manageable cost of doing business, particularly if they resolve liability without admissions of wrongdoing and avoid criminal charges against key executives. Facility closures effectively remove a non-compliant provider but can disrupt care continuity for patients. HHS-OIG exclusion is a powerful tool protecting federal programs from known bad actors , but excluded individuals or entities might still operate using private funds. Corporate Integrity Agreements (CIAs) impose structured compliance obligations and independent oversight, potentially fostering long-term change but requiring significant monitoring resources from OIG. Criminal prosecutions resulting in imprisonment offer the strongest deterrent for individuals involved in fraud or abuse.
• State vs. Federal Roles: While federal agencies (DOJ/OIG) drive the largest financial recoveries through FCA and AKS enforcement, state agencies play vital roles in licensing, routine compliance, and addressing patient safety issues. However, evidence from states like California suggests that state regulatory enforcement can sometimes be weak, with facilities accumulating numerous safety violations without facing significant penalties like fines or admission halts, potentially allowing harmful conditions to persist.
• Whistleblower Importance: The prevalence of qui tam lawsuits resolved in major settlements underscores the indispensable role of whistleblowers (often current or former employees) in bringing large-scale fraud to the attention of authorities. Without insiders reporting misconduct, many complex schemes might go undetected.
• Ongoing Challenge: Despite significant enforcement efforts and recoveries totaling billions annually, the continued emergence of large-scale fraud schemes (like the Arizona sober home case) and the record number of new qui tam filings indicate that fraud and abuse remain persistent challenges in the behavioral health sector.

A significant portion of the enforcement actions detailed in this report appear to be reactive rather than proactive. Major investigations and settlements often follow whistleblower reports (qui tam lawsuits under the FCA) , patient complaints, media exposés , or tragic events like patient deaths. While proactive measures exist, such as routine state Medicaid audits , OIG audits , and collaborative data analysis initiatives like the Healthcare Fraud Prevention Partnership (HFPP) , the sheer volume and scale of the fraud uncovered suggest these mechanisms may be insufficient to detect and prevent widespread abuse early on. The Arizona sober living scheme, for example, reportedly operated and caused harm for a considerable period before large-scale state intervention occurred. This reactive posture means that significant harm—both financial and to patients—may occur before enforcement action is taken.

Furthermore, the reliance on large financial settlements as the primary resolution for corporate misconduct raises questions about deterrence. While settlements in the tens or hundreds of millions of dollars are substantial, for multi-billion dollar corporations, they may not represent an existential threat. If settlements resolve civil liability without admissions of wrongdoing and without accompanying criminal charges against high-level executives responsible for the corporate culture or policies that enabled the fraud, the penalty might be viewed internally as a “cost of doing business” rather than a catalyst for fundamental change. The continued operation of major providers after significant settlements, albeit often under the stricter oversight of a CIA , supports this concern. While CIAs aim to impose compliance discipline, their effectiveness depends on rigorous monitoring. OIG’s creation of the “Heightened Scrutiny” list for providers refusing appropriate integrity obligations is an attempt to address this gap, but its long-term impact remains to be seen. The disparity between severe criminal penalties (including imprisonment) often faced by individual perpetrators and the typically civil resolution for the corporate entities involved may dilute the deterrent message at the organizational level.

E. Data Gaps and Transparency Issues

Compiling a comprehensive list of sanctioned facilities faces significant hurdles due to data fragmentation and lack of transparency. As highlighted in the Ohio findings, there is often no single, publicly accessible state or federal database that lists all treatment facilities closed or fined specifically for the full range of ethical and illegal activities, particularly organized by county or locality. Existing databases like the OIG LEIE focus on exclusion , licensing board databases often center on individuals , and NPDB is confidential and individual-focused. Information on reasons for sanctions can be vague or difficult to access. Even official resources may contain inaccuracies; an OIG audit found SAMHSA’s FindTreatment.gov locator had inaccurate information for a significant percentage of sampled facilities. This lack of centralized, detailed, and easily accessible data hinders comprehensive tracking and analysis of enforcement actions at the facility level.

VI. Recommendations and Conclusion

A. Recommendations

Based on the analysis of enforcement actions and identified challenges, the following high-level recommendations are proposed:

• For Regulators and Policymakers:

• Strengthen State Oversight: Enhance state-level regulations governing facility licensure, mandating minimum staffing ratios based on patient acuity, and implementing more robust enforcement penalties. Consider mandatory fines, temporary admission halts, or expedited license suspension/revocation proceedings for facilities with repeated serious violations related to patient safety or fraud.
• Improve Transparency: Develop and maintain publicly accessible, searchable state-level databases that clearly list disciplinary actions, significant fines, settlements, and closures specifically for licensed behavioral health facilities, including the nature of the violation and the action taken.
• Standardize Patient Brokering Laws: Advocate for or enact strong, consistent state laws mirroring or exceeding EKRA’s prohibitions against patient brokering and illegal kickbacks in the addiction treatment sector, ensuring clear definitions and felony-level penalties.
• Enhance Proactive Detection: Increase funding and resources for proactive measures, including unannounced state inspections focused on quality of care and compliance, sophisticated data analytics by Medicaid programs and OIG to identify aberrant billing patterns earlier, and targeted audits of high-risk provider types.
• Improve Agency Coordination: Foster better communication and data sharing protocols between state licensing boards, state MFCUs, state health departments, state auditors, and federal partners (DOJ, OIG, FBI, DEA) to ensure coordinated and timely enforcement responses.
• Address Data Integrity: Implement stricter validation procedures for information included in public-facing treatment locators and databases to ensure accuracy and timeliness.
• Target Vulnerable Populations: Develop specific regulatory safeguards and outreach programs to protect populations frequently targeted by fraudulent schemes, such as individuals experiencing homelessness or members of Native American communities.
• For Providers:

• Implement Robust Compliance Programs: Establish comprehensive compliance programs based on the OIG’s Seven Elements, including written policies and procedures, designated compliance personnel, effective training, auditing and monitoring, and mechanisms for reporting potential violations.
• Conduct Diligent Exclusion Screening: Regularly screen all employees, contractors, and vendors against the HHS-OIG LEIE and relevant state exclusion lists upon hiring/contracting and periodically thereafter (e.g., monthly) to prevent CMP liability.
• Uphold Ethical Standards: Ensure adherence to professional codes of ethics and facility-specific codes of conduct, emphasizing patient welfare, confidentiality, and avoidance of conflicts of interest.
• Provide Comprehensive Training: Conduct regular, mandatory training for all staff on relevant federal and state laws (FCA, AKS, EKRA, HIPAA, state licensure), facility policies, documentation requirements, patient rights, and recognizing/reporting potential fraud, waste, abuse, or neglect.
• Establish Non-Retaliatory Reporting: Create clear, accessible channels for employees and patients to report concerns about compliance, ethics, or patient safety internally, with strong policies prohibiting retaliation against good-faith reporters.
• Scrutinize Business Relationships: Carefully vet all marketing, referral, and vendor relationships to ensure strict compliance with the AKS, EKRA, and Stark Law, avoiding arrangements that could be construed as improper inducements. Obtain legal review for complex arrangements.
• Prioritize Patient Safety & Quality: Ensure adequate staffing levels, proper supervision, evidence-based treatment protocols, and adherence to all patient safety regulations.
• For Consumers and Advocates:

• Exercise Due Diligence: Verify facility licensing status with state agencies and check for accreditation (e.g., CARF, Joint Commission) before seeking or referring treatment. Research facility reputation and any publicly available disciplinary history.
• Be Wary of Inducements: Be cautious of unsolicited offers of treatment, promises of free services (including travel or housing), high-pressure sales tactics, or cash payments for attending a specific facility, as these can be indicators of patient brokering schemes.
• Report Suspected Wrongdoing: Promptly report concerns about potential fraud, patient abuse or neglect, unsafe conditions, or unethical practices to the appropriate authorities. This includes state licensing boards, the state Attorney General’s office (especially the MFCU for Medicaid issues ), the state Department of Health or Mental Health/Addiction Services , federal hotlines like the HHS-OIG Hotline (1-800-HHS-TIPS) or the FBI’s Internet Crime Complaint Center (IC3) , and relevant accrediting bodies.
• Review Billing Statements: Carefully review Explanation of Benefits (EOBs) from insurers and billing statements from providers to ensure accuracy regarding dates of service, services received, and providers seen. Report any discrepancies to the insurer and provider.

B. Concluding Remarks

The behavioral health sector plays an indispensable role in addressing critical societal needs related to mental illness and substance use disorders. However, the inherent vulnerability of the patient population, combined with the significant financial flows from public and private payors, creates an environment susceptible to fraud, abuse, and neglect. The documented enforcement actions in Ohio and nationwide, involving multi-million dollar settlements, facility closures, criminal convictions, and findings of patient harm, underscore the reality and severity of these risks.

While numerous behavioral health providers operate ethically and provide essential care, the patterns of misconduct identified in this report—ranging from sophisticated financial fraud and illegal kickback schemes to devastating failures in patient safety—demand ongoing and robust vigilance from regulators, providers, and the public. Achieving a balance between ensuring access to necessary care and implementing stringent oversight to protect patients and taxpayer funds remains a critical challenge. Continuous improvement in regulatory frameworks, enforcement strategies, provider compliance efforts, and public awareness is essential to foster a behavioral healthcare system characterized by integrity, quality, and safety.

VII. Appendices

Glossary of Key Terms

• AKS (Anti-Kickback Statute): Federal criminal law prohibiting payments to induce referrals for items/services covered by federal healthcare programs.
• CIA (Corporate Integrity Agreement): An agreement between HHS-OIG and a healthcare provider following a settlement, imposing compliance obligations and monitoring for a set period (typically 5 years).
• CMPL (Civil Monetary Penalties Law): Federal law authorizing HHS-OIG to impose fines and exclusions for various healthcare violations.
• CMS (Centers for Medicare & Medicaid Services): Federal agency administering Medicare and overseeing Medicaid.
• DOJ (Department of Justice): Federal agency responsible for enforcing federal laws, including prosecuting healthcare fraud and negotiating FCA settlements.
• EKRA (Eliminating Kickbacks in Recovery Act): Federal law specifically prohibiting kickbacks and patient brokering related to recovery homes, clinical treatment facilities, and labs, applicable to all payors.
• FCA (False Claims Act): Federal law imposing liability for knowingly submitting false claims to the government; includes qui tam (whistleblower) provisions.
• FBI (Federal Bureau of Investigation): Primary federal agency investigating many types of crime, including healthcare fraud.
• HHS-OIG (Department of Health and Human Services Office of Inspector General): Agency responsible for protecting the integrity of HHS programs (like Medicare/Medicaid) through audits, investigations, exclusions, and CMPs.
• LEIE (List of Excluded Individuals/Entities): Database maintained by HHS-OIG listing parties excluded from federal healthcare programs.
• MFCU (Medicaid Fraud Control Unit): State-level units, often within the Attorney General’s office, responsible for investigating and prosecuting Medicaid provider fraud and patient abuse/neglect.
• NPDB (National Practitioner Data Bank): Confidential federal database tracking malpractice payments and adverse actions against individual healthcare practitioners.
• Qui Tam: Provision of the False Claims Act allowing private individuals (whistleblowers/relators) to file lawsuits on behalf of the government and share in any recovery.
• Stark Law: Federal law prohibiting physician self-referrals for designated health services payable by Medicare/Medicaid if a financial relationship exists, unless an exception applies.