Therapy as a billing driver
Medicare pays separately or through bundled rates for physical, occupational, and speech therapy. Facilities where therapy revenue drives margins may push clinicians to document more minutes than delivered or treat patients who cannot benefit.
Typical schemes
Billing ultra-high therapy minutes (including group therapy counted incorrectly), treating unresponsive or hospice patients for intensive rehab, and upcoding therapy complexity are patterns seen in government settlements.
Insider witnesses
Therapists asked to sign off on minutes they did not perform, or told that patient tolerance does not matter for billing targets, may be witnessing fraud — not just aggressive business practices.
FCA enforcement
Therapy fraud cases often combine medical necessity falsehoods with false claims for payment. Relators with documentation of corporate policies tying bonuses to therapy volume have helped DOJ recover millions.