In a significant development in the ongoing battle against healthcare fraud, Forefront Dermatology S.C. and Henghold Surgery Center LLC have agreed to pay a combined $847,394 to resolve allegations that they knowingly submitted falsely coded claims to Medicare, according to a release from the U.S. Department of Justice.
Background: Improper Billing Practices
The allegations stem from the billing practices of Henghold Dermatology, a Florida-based practice operated by Forefront, and the now-closed Henghold Surgery Center, an ambulatory surgery facility wholly owned by Dr. William B. Henghold. Both entities performed wound repairs following Mohs micrographic surgery, a precise technique used to treat skin cancer.
According to the Justice Department, the providers submitted upcoded claims to Medicare—billing for more expensive wound repair procedures than were actually performed. This included falsely categorizing simple linear repairs as more complex flap repairs, and misreporting the size of flap repairs to receive inflated reimbursements.
The Government’s Response
Assistant Attorney General Brett A. Shumate of the DOJ’s Civil Division emphasized the gravity of the misconduct:
“Improperly billing Medicare depletes valuable government resources that provide necessary medical care to millions of Americans. We will hold accountable health care providers who enrich themselves by defrauding federal health care programs.”
U.S. Attorney John P. Heekin for the Northern District of Florida echoed the sentiment:
“This office will continue to aggressively root out fraud, waste, and abuse in our healthcare system by pursuing providers who submit false claims to Medicare.”
Deputy Inspector General Christian J. Schrank of HHS-OIG added:
“Schemes that cause Medicare to pay for costlier services than were actually performed waste taxpayer funding, threatening the integrity of this federal health care program.”
Whistleblower Played a Key Role
The resolution stems in part from a whistleblower lawsuit filed under the False Claims Act’s qui tam provisions by Dr. Christopher Wolfe, a former Forefront employee. These provisions allow private citizens to sue on behalf of the federal government and share in any recovery.
Dr. Wolfe will receive $152,531 as his share of the settlement—a testament to the critical role whistleblowers continue to play in exposing fraud.
The qui tam case is titled U.S. ex rel. Wolfe v. Henghold et al., No. 3:23-cv-21624 (N.D. Fla.).
Broader Implications
This case illustrates the ongoing scrutiny of healthcare billing practices, especially in high-volume and high-reimbursement areas such as dermatology and outpatient surgical care. The Justice Department and HHS-OIG remain active in investigating coding irregularities and will continue to target schemes designed to maximize profits at the taxpayer’s expense.
Key Takeaways for Providers
- Accurate coding is essential. Providers must ensure that documentation supports billed services, especially when distinguishing between levels of wound repair.
- Audits and internal compliance programs are more important than ever to detect and prevent false claims.
Need help navigating compliance risks in wound care coding? Contact our office for a consultation.
