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Yasmin Hoffmann, CFE, PMP
Research Project Manager

Fraud is pervasive in the health care field, but one area that has recently come into focus is the ambulance transport industry. While most emergency vehicle providers are ethical, there are a few out there who have taken a detour down the wrong road. Here are examples of common fraud schemes to look out for in this industry, along with real-life examples of when these schemes were perpetrated.

Billing and Fraudulent Documentation

One scheme is to bill for advanced life support (ALS) services when only basic life support (BLS) services are needed. An example is if documentation is falsified to state that the patient required oxygen during transport when in reality, it was not provided.

Another common billing fraud scheme is when an ambulance charges for more miles than were actually traveled during the ride. Air ambulance services have also been found to falsify mileage by charging for ground miles instead of nautical miles, typically using something like Google Maps as a marker.

In 2018, Anthony Chukwudi Nwosah, owner of Tonieann EMS and Rosenberg EMS, admitted to instructing his emergency medical technician (EMT) to fake records, which included fake vital signs and transport mileage. He also confessed to an additional 2,000 fake records that contained a name of an EMT that did not exist. He knowingly submitted more than $3 million in fraudulent claims to the health care system. Nwosah now faces up to 10 years in federal prison and a $250,000 fine.

Billing non-emergency trips as emergency trips is another popular scheme. This might occur when an ambulance company offers to take an elderly patient to their doctor or hospital for follow-up examinations but then bills these visits as much more costly emergency transports. In 2018, Keeble Lovall, the owner of Your Health EMS, was found guilty for his role in committing health care fraud by falsely billing U.S. government programs (Medicare and Medicaid) for non-eligible ambulance transports. Lovall would submit claims for individual ambulance transports, even though multiple patients were transported to appointments via one ambulance. His company would drive Medicare patients to Partial Hospitalization Programs (PHPs), which is not covered by Medicare. In addition, Your Health EMS provided transportation services where there was no medical necessity. Overall, Lovall billed Medicare approximately $2.8 million, and received more than $1 million back into his company’s bank account. He received a 63-month sentence following his conviction.

In a variation of this, the city of Tehran in Iran recently reported the abuse of emergency-service vehicles by celebrities and wealthy citizens. In this scam, some were found to be hiring ambulances to act as a private chauffer to bypass traffic jams because of their ability to ignore traffic signals and other drivers are required to provide a clear path to destinations. Once the community heard of this, public distrust of emergency vehicles made it more difficult for them to transport actual patients because drivers refused to clear roads, assuming it was a non-emergency. While there were no financial losses in this variation of the scheme, it’s still worth a mention because of the severe erosion of trust and, like many health care fraud schemes, the potential for deadly consequences.

Kickbacks

Kickbacks are not always of monetary value. They can also come in the form of providing discounts or gifts to medical institutions or providers in exchange for transportation referrals. For example, some nursing homes will offer exclusive transportation arrangements in exchange for taking patients to or from routine visits. Hospitals might pay kickbacks for ambulances to bring patients to their facility rather than to another hospital, even if the other option is closer.

In 2002, four Texas-based hospitals violated the U.S. Anti-Kickback Statute and paid $8.6 million to resolve the allegations. In this scheme, the hospitals worked with various ambulance companies in order to receive discounted transportation services in exchange for referring Medicare and Medicaid patients directly to the companies involved in the fraudulent relationship. The emergency rides provided were as low as $25 compared to the standard $500 rides these companies generally charge, which allowed these hospitals to save a large sum of money.

In August 2018, East Texas Medical Center Regional Health Services Inc. and their affiliate ambulance company, Paramedics Plus LLC, paid a $21 million settlement to resolve a whistleblower claim alleging illegal kickbacks. Dr. Stephen Dean claimed Paramedics Plus paid bribes in the form of political contributions to elected officials in order to gain EMS contracts in California, Texas, Oklahoma and Florida. Kickbacks were disguised as an arrangement called a profit cap, in which the ambulance company would receive an overpriced contract and the extra profits would transfer into a trust or third party.

Regulatory or Licensing Violations

An emergency vehicle service might bill for routine transportation services without a valid Physician Certification Statement (PCS), which is a written order certifying the medical necessity of non-emergency transports. An ambulance might even operate without having a licensed health care provider, or EMT, on staff. Houman Motii, the owner of Swift Medical Transport, a Virginia-based private ambulance service, hired employees who had not passed their EMT examinations and drove without valid driver’s licenses. Employees admitted to taking patients to appointments without knowledge of how to use a defibrillator, and in one case had to detour to the nearest hospital when a patient went into cardiac arrest. During the investigation, it was also found that drivers were suspected of working while under the influence. Ambulances were also operating with empty or nearly empty oxygen cannisters. In 2019, Motii was sentenced to 13 months in federal prison for his role in regulatory and licensing violations, as well as billing fraud.

Ambulance transport fraud not only cheats the government, but also taxpayers, and fraud examiners who work in the health care fraud realm should be on the lookout for schemes like these. While this list of emergency vehicle fraud schemes is not exhaustive, it’s always beneficial to build up your knowledge of different schemes and how they work.

Detecting and preventing health care fraud schemes can be very complex and difficult. Upcoding, unbundling, rolling lab schemes and medical identity theft are all methods fraudsters use to bilk money out of the health care system. If you’d like to get more familiar with the different types of schemes, our online self-study course “10 Common Health Care Fraud Schemes” explores 10 common health care fraud schemes as well as tips for preventing and detecting the schemes.

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