A Missouri-based nonprofit behavioral health provider has admitted making criminal false statements in claims for services not provided to foster youth and agreed to a series of compliance measures, federal and state officials announced Friday.
In a separate civil settlement, Great Circle of Webster Groves, Missouri agreed to pay $1,866,000, consisting of $933,000 in restitution that was doubled under the False Claims Act.
“In this non-prosecution agreement, Great Circle admits falsely claiming to have provided enhanced supervision to youth at its residential treatment facility in claims for payment to the State of Missouri,” said Assistant U.S. Attorney Meredith Reiter, who is leading the team that worked on the case. “A cascade of issues can arise from inadequate supervision, particularly for children with such intensive need for treatment and assistance.”
“These agreements hold Great Circle accountable by requiring it to admit false billing and pay a civil false claims settlement, without jeopardizing continued access to residential treatment services for children in Missouri’s foster care program,” Reiter said.
The non-prosecution agreement (NPA) was entered into for, among other reasons, the nonprofit’s past and continuing cooperation, the lack of prior criminal history, and the $1.8 million civil settlement agreement. A major consideration was also the fact that the nonprofit has been providing behavioral health services to children with special needs in the custody of the Missouri Department of Social Services, Children’s Division, and a criminal conviction resulting in exclusion from federal programs could jeopardize that and thus cause hardship to innocent third parties.
The multi-year investigation and these agreements are the results of a coordinated effort among the U.S. Attorney’s Office for the Eastern District of Missouri, the Office of Inspector General of the Department of Health and Human Services, the Missouri Department of Social Services, the FBI, the Webster Groves Police Department, and the Phelps County Sheriff’s Department.
“Great Circle falsely submitted bills for services it did not provide but were needed by the children,” said Special Agent in Charge Jay Greenberg of the FBI St. Louis Division. “Prioritizing profit over safety can put already vulnerable children in peril.”
“To obtain ill-gotten gains, Great Circle knowingly submitted false claims related to services that are intended to benefit children,” stated Curt L. Muller, Special Agent in Charge with the Department of Health and Human Services Office of Inspector General. “We commend the efforts of our agents and law enforcement partners to hold Great Circle accountable and safeguard the integrity of our federal programs that support health and human services.”
“I’m committed to enforcing the law as written, and that involves ensuring that anyone who defrauds the state is held accountable,” said Missouri Attorney General Andrew Bailey. “I’m proud of the collaboration between this office’s Medicaid Fraud Control Unit and our law enforcement partners to obtain restitution for the state, and we will continue to ensure that those who cheat the state are brought to justice.”
“Following a multi-year investigation of Great Circle related to allegations of abuse of child health care recipients, allegations of failure to report abuse, and Medicaid fraud, we are pleased with the results,” said Lt. Jillian McCoy of the Webster Groves Police Department. “The ultimate goal of serving and protecting vulnerable youth was obtained by cooperative efforts with federal agencies through the U.S. Attorney’s Office.”
“Our goal is to ensure every child across the state lives in a safe, nurturing environment that will ultimately help them thrive,” said Robert Knodell, acting director for the Missouri Department of Social Services. “The Department of Social Services is pleased to assist in holding Great Circle accountable for its actions without further jeopardizing the care of some of Missouri’s most vulnerable youth. We are sending a strong message regarding the care we expect our children to receive, and we will continue to do whatever it takes to help ensure the safety and well-being of Missouri’s children.”
As part of the agreement, Great Circle admitted falsely claiming to have provided services for six residents between 2019 and 2020. Great Circle is licensed to provide “intensive residential treatment” services to children, also known as Level IV services, and is defined as providing a “highly structured and secure environment designed to (a) prevent emotionally disturbed youth from runaway behavior; (b) address the likelihood of rage and physical aggression by the residents; and (c) minimize the likelihood of youth injuring themselves or others.”
On multiple occasions, Great Circle falsely claimed to have provided services above Level IV, including increased ratios of staff to residents and other enhanced services.
The company agreed to cooperate with the government in any additional healthcare fraud investigation and to promptly report any credible evidence or allegations of conduct violating U.S. law to the U.S. Attorney’s Office. Great Circle also has agreed to implement a compliance and ethics program designed to prevent and detect violations of federal fraud and related statutes and adopt new or modify existing internal controls, compliance codes, and policies and procedures where necessary. Officers, directors, and senior management will have to “provide strong, explicit, and visible support and commitment” to the corporate policy against violations of relevant laws.
Great Circle has locations throughout Missouri and in Kansas. KVC Missouri has announced it will take over Great Circle on April 1.
Assistant U.S. Attorneys Meredith Reiter, Suzanne Moore, and Gwendolyn Carroll handled the case.
