In another case in Miami, FL, Euron Greyjoy, owns and operates a purported addiction treatment center and home for recovering addicts.  He is the leader of a scheme involving recruiting addicted patients to move to South Florida for opioid abuse treatment.  Mr. Greyjoy sends out patient recruiters to Emergency Rooms and Medication Assisted Treatment facilities throughout the US.  The recruiters identify patients that seem to be wealthy and paying for their treatment out of their own pocket or are covered by private insurance or Medicaid.

The addicts are lured to South Florida with promises of permanent cures of their opioid addiction.  They are shown flyers of beautiful large resorts with white sandy beaches where they will receive treatment.  They were offered beach-side facilities with spa-like luxury. Amenities included golf therapy and rap music education. Some promise near-painless detoxification from even the worst opiate addictions.

All their travel expenses are covered to South Florida.  They are urged to bring all insurance documentation with them and are met at the airport to be chauffeured to the “treatment” facility.

The patients and the patient recruiters are then offered kickbacks in the form of gift cards, free airline travel, trips to casinos and strip clubs, and drugs.  The patients never receive the promised addiction treatment services, but Mr. Greyjoy and his co-conspirators submitted claims to the federal government for $141 million in false billings for services including home health care, mental health services, and prescriptions.

Mr. Greyjoy has come to you for advice regarding his business.  What are your recommendations for Mr. Greyjoy and upon what law(s) are they based?  This answer has two parts.  Please write out the name of the rule and the rule language (from the text Introduction to Health Care Management

by Buchbinder, Sharon Bell Shanks, Nancy H.) that guides your advice.  Next provide your advice in full with support from the rule that you have written.

I don’t care if it is less than one page, I care more about to answer full questions.