On February 3, 2025, in United States ex rel. Wheeler v. Acadia Healthcare Co., the Fourth Circuit reversed a district court's dismissal of a qui tam case brought against Acadia, which is one of the largest addiction treatment and behavioral healthcare service providers in the United States. The circuit court held that the requirements of a Corporate Integrity Agreement (CIA) can give rise to obligations that trigger a reverse false claim, creating a split with the Sixth Circuit, which considered the same issue involving a CIA with similar provisions in 2018 and reached the opposite conclusion.
The relator, who was the former Assistant Medical Director of one of Acadia's North Carolina clinics, accused the company of fraudulently collecting Medicare and Medicaid reimbursements for therapy and counseling sessions it never conducted. The relator claimed that therapists and counselors at Acadia facilities were falsifying medical records for patients experiencing opioid use disorder, and relying on these records to submit claims to the government for payment.
Amongst a host of other False Claims Act...
