The Department of Justice charged a 46-year-old Palm Beach County doctor with committing health care fraud and wire fraud. The charges were the result of an alleged multi-million-dollar scheme.
Michael J. Ligotti, D.O. allegedly billed private health care companies and Medicare between May 2011 and March 2020 for fraudulent tests and treatments for patients seeking treatment for drug and/or alcohol addiction. The total sum of the fraudulent scheme was $681 million. Ligotti allegedly received $121 million in payments from insurance companies.
Dr. Ligotti owned and operated Whole Health, a private clinic in Delray Beach, that offered a variety of services, including family care, urgent care and even additional treatment.
According to the DOJ, Liggotti:
- Agreed to become the purported “Medical Director” for an addiction treatment facility or sober home for a nominal fee.
- Authorized “standing orders” for hundreds of millions of dollars in medically unnecessary urinalysis tests (UAs), which were billed by testing laboratories that sometimes paid kickbacks to the sober homes or addiction treatment facilities
- In exchange for his signature on these standing orders, required the facilities to have their patients treated by Whole Health and his staff, allowing him to bill hundreds of millions of dollars in additional fraudulent treatments, including unnecessary and expensive [urinary analysis], costly blood tests, non-existent therapy sessions, office visits, and other unnecessary services, regardless of whether such treatment and testing were medically necessary and/or actually provided. Ligotti allegedly did not meaningfully review the results of the tests he ordered or use the results of the tests to treat these patients, either at his clinic or at the addiction treatment facilities.
Part of the scheme reportedly including Ligotti serving as a "Medical Director" for more than 50 addiction treatment facilities. He allegedly signed over 136 standing orders authorizing various fraudulent tests.
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When patients arrived at one of the various addiction centers and sober homes, they were required to undergo whatever treatment and testing Ligotti prescribed, some of which included unnecessary urinary analysis tests.
According to the DOJ, all parties involved benefited from the scheme:
(1) the laboratories could bill for these medically unnecessary tests; (2) the addiction treatment facilities and sober homes could bill for such unnecessary testing as well, and sometimes received a kickback from the laboratories for each sample they could provide for testing; and (3) Ligotti could bill millions of dollars’ worth of medically unnecessary, excessive and duplicative treatments for the patients who were delivered to his office as the condition for him signing the standing orders that fueled the entire scheme in the first place.
The complaint further alleges that Ligotti authorized and conducted UAs and blood tests for revenue-generation but did not use these tests in patient treatment. Ligotti allegedly billed for psychiatric services and therapy sessions that never happened and that Ligotti and his staff were not qualified to conduct. Some patients allegedly were billed between $10,000 and $20,000 by Ligotti and Whole Health for a single day’s visit. As charged, Ligotti also utilized multiple nurse practitioners/medical extenders under his practice to fraudulently bill patients’ private insurance. Finally, the complaint alleges that Ligotti improperly prescribed controlled substances, including large quantities of buprenorphine/Suboxone, frequently exceeding the number of patients he was legally authorized to treat. He provided these drugs to patients who did not need it and ignored evidence of possible diversion.
"He provided these drugs to patients who did not need it and ignored evidence of possible diversion," the Justice Department stated.
