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?

You recently became aware of your friend’s actions because your loved one is a resident at one of the homes where the dentist’s visits.

What advice would you give to the dentist after reading Chapter 15 of Showalter and consulting the case United States v. Lorenzo. 

In another scenario, you have a friend, Robert Baratheon, who is a physician, and whose ex-wife, Cersei Lannister, owns a durable medical equipment supply company, Lannister Home Care, in King of Prussia. Dr. Baratheon can refer patients to the durable medical supply store where they obtain their hospital beds, walkers, crutches, oxygen bottles, and motorized scooters, among other supplies. The patients receive a special discount when they are referred to Lannister Home Care and they greatly appreciate the savings. Many of the patients would not be able to afford their purchases without this discount and this referral pattern has saved the patients tens of thousands of dollars.

In turn, Lannister Home Care gives a monthly bonus to your physician friend based on the sales that the patients referred by his practice generate in equipment and supplies. Your friend is under the impression that the monthly bonus is given to him because he provides patients a list of all durable medical equipment stores in the area. In his mind, there is no overt referral to Lannister Home Care. However, the bonus increases and decreases based on the number of patients that come from his practice. The Dr. Baratheon never sees these increases and decreases in the bonus because his billing manager intentionally never reveals it to him and he never knows to ask. He just assumes that all is being lawfully run. Lannister Home Care bills Medicare or the patient’s health insurance company if the item is covered by the patient’s insurance plan.

What advice do you give to your friend, Dr. Baratheon?

In 2005, another physician friend, Jaime Lannister (twin brother to Cersei) who lives in Westeros became one of the owners of a 50-bed physician specialty hospital that specializes in knee, hip, and shoulder replacement surgeries. He is a member of a group of physicians who own 100% of the hospital and perform all their replacement surgeries in the hospital. The group of physicians hires all the staff and has purchased all the equipment at fair market value. Your friend sees all his patients at a separate office and refers all patients that require replacement surgeries to the hospital that is owned by the physician group, of which he is a full member.

What advice do you have for your physician friend after the Affordable Care Act went into effect in 2010?

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 4

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?