Monthly Archives: December 2013

FORMER CONTRACTOR OF A FLORIDA PROPERTY MANAGEMENT COMPANY SENTENCED TO SERVE TIME IN PRISON FOR WIRE FRAUD

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WASHINGTON —A former repair contractor of a  Florida property management company was sentenced to serve time in prison for his  participation in a wire fraud scheme related to housing repairs made under a  contract between Ocwen Loan Servicing LLC, and the U.S. Department of Veterans  Affairs (VA), the Department of Justice announced today.

Ronald B. Hurst was sentenced by  Judge Philip G. Reinhard of the U.S. District Court for the Northern District  of Illinois in Rockford to serve 24 months in prison for his role in the  conspiracy.

In addition, a second former repair  contractor, Bryant A. Carbonell, was sentenced by Judge Reinhard to serve six  months of home confinement for his role in the conspiracy.  Hurst and Carbonell were sentenced to pay $147,825  jointly and severally in restitution to the VA.  Hurst pleaded guilty on Feb. 15, 2013, to two  wire fraud counts of a 10-count indictment and Carbonell pleaded guilty on  Sept. 21, 2012, to the same charges.

An indictment, originally filed in  January 2012, charged Hurst, Carbonell and Ryan J. Piana with conspiring to  commit bribery and wire fraud from at least January 2006 until as late as  September 2007.  Hurst, Carbonell and Piana  were also charged with bribery and wire fraud.  As part of the plea agreements, the United  States agreed to dismiss the remaining counts against Hurst and Carbonell at  the time of their sentencing.
“By paying kickbacks in exchange for  contracts to companies they secretly owned or with which they were affiliated,  the conspirators created the illusion of competition while illegally steering  contracts to themselves,” said Bill Baer, Assistant Attorney General in charge  of the Department of Justice’s Antitrust Division.  “Today’s sentencing reaffirms the Antitrust  Division’s commitment to prosecuting schemes that undermine competition in the  VA Mortgage Guarantee Program.”
Hurst and Carbonell were former  contractors for West Palm Beach, Fla.-based Ocwen Loan Servicing LLC. Piana was  a former residential sales manager at Ocwen.  According to court documents, Ocwen managed  foreclosed properties under contract with the VA, which guaranteed qualifying residential  mortgages for veterans.  Under the  contract between the VA and Ocwen, if a veteran defaulted, Ocwen completed  necessary repairs and re-sold the property.  Proceeds from the re-sale of VA-acquired  properties directly benefit the VA by reducing the cost of guaranteeing  residential mortgages to veterans.
According to the charges, Hurst and  Carbonell paid Piana to steer housing repair work to companies affiliated with Hurst  and Carbonell.  Piana recruited other  Ocwen employees into the scheme and paid them on behalf of himself and the  other conspirators.  The department said  in order to execute the scheme, the conspirators sent, or caused to be sent,  various transmissions via wire communication.
This is the third case involving  properties managed by Ocwen under contract with the VA. On Dec. 3, 2010,  Benjamin K. Graves, also a former Ocwen employee, pleaded guilty in U.S.  District Court in Orlando, Fla., to wire fraud in connection with the VA contract.   On Jan. 25, 2012, Joshua R. Nusbaum,  another former Ocwen employee, and Andrew J. Nusbaum, a former Ocwen  contractor, pleaded guilty in U.S. District Court in Orlando, Fla., to wire  fraud in connection with the same VA contract.  Piana pleaded guilty to the same counts as  Carbonell and Hurst on July 16, 2013, in U.S. District Court in Orlando, Fla.  Piana was sentenced on Sept. 30, 2013, to serve  24 months in prison and to pay $147,285 in restitution to the VA.

The sentence announced today resulted  from a federal investigation of housing repair contracts performed under  contract with the VA.  The investigation  is being conducted by the Antitrust Division’s Chicago Office and the Central  Field Office of the U.S. Department of Veterans Affairs, Office of Inspector  General, Criminal Investigations Division, located in Hines, Ill. Anyone with  information concerning suspicious activity relating to housing repairs  performed under a contract with the VA should contact the Antitrust Division’s Chicago Office at 312-353-7530 or visit  www.justice.gov/atr/contact/newcase.htm.

TWO NORTHERN CALIFORNIA REAL ESTATE INVESTORS AGREE TO PLEAD GUILTY TO BID RIGGING AT PUBLIC REAL ESTATE FORECLOSURE AUCTIONS

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WASHINGTON — Two Northern California real estate investors have agreed to plead  guilty for their roles in conspiracies to rig bids and commit mail fraud at  public real estate foreclosure auctions in Northern California, the Department  of Justice announced.

Felony charges were filed today in the U.S. District Court for the  Northern District of California, in San Francisco, against Florence Fung of  Sacramento, Calif, and Michael Navone of San Rafael, Calif.  Fung and Navone are  the 39th and 40th individuals to plead guilty or agree to  plead guilty as a result of the department’s ongoing antitrust investigations  into bid rigging and fraud at public real estate foreclosure auctions in  Northern California.

According to court documents, Fung and Navone conspired  with others, for various lengths of time between February 2009 and January  2011, not to bid against one another, but instead to designate a winning bidder  to obtain selected properties at public real estate foreclosure auctions in San  Mateo County.  Fung and Navone  also were charged with conspiring to use the mail to carry out schemes to  fraudulently acquire title to selected properties sold at public auctions, to  make and receive payoffs and to divert money to co-conspirators that would have  gone to mortgage holders and others.  Navone  was also charged with participating in similar conspiracies in San Francisco  County beginning as early as October 2009 until about January 2011.

“Instead of competing at real estate foreclosure auctions, the  conspirators agreed not to bid against one another and determined among themselves  who would submit the winning bid, stifling honest and fair competition,” said Bill  Baer, Assistant Attorney General in charge of the Department of Justice’s  Antitrust Division. “The Antitrust Division and its partners at the FBI  continue to remain committed to holding accountable investors who attempt to  subvert the competitiveness of the bidding process.”

The department said that the primary purpose of the  conspiracies was to suppress and restrain competition and to conceal payoffs in  order to obtain selected real estate offered at San Mateo and San Francisco county  public foreclosure auctions at non-competitive prices.  When real estate properties are sold at these  auctions, the proceeds are used to pay off the mortgage and other debt attached  to the property, with remaining proceeds, if any, paid to the homeowner. According  to court documents, these conspirators paid and received money that otherwise  would have gone to pay off the mortgage and other holders of debt secured by  the properties, and, in some cases, the defaulting homeowner.

“The FBI continues to join the Antitrust Division in  holding criminals accountable for bid rigging and fraudulent practices at  public real estate foreclosure auctions,” said David J. Johnson, FBI Special  Agent in Charge of the San Francisco Field Office.  “Anticompetitive practices disrupt a fair  marketplace and the FBI will investigate these types of crimes.”

A violation of the Sherman Act carries a maximum penalty of  10 years in prison and a $1 million fine for individuals.  The maximum fine for the Sherman Act charges  may be increased to twice the gain derived from the crime or twice the loss  suffered by the victims if either amount is greater than $1 million.  A count of conspiracy to commit mail fraud  carries a maximum sentence of 30 years in prison and a $1 million fine.  The government can also seek to forfeit the  proceeds earned from participating in the conspiracy to commit mail fraud.

Today’s charges are the latest filed by the department in  its ongoing investigation into bid rigging and fraud at public real estate  foreclosure auctions in San Francisco, San Mateo, Contra Costa, and Alameda counties,  Calif.  These investigations are being  conducted by the Antitrust Division’s San Francisco Office and the FBI’s San  Francisco Office.  Anyone with  information concerning bid rigging or fraud related to public real estate  foreclosure auctions should contact the Antitrust Division’s San Francisco Office  at 415-436-6660, visit www.justice.gov/atr/contact/newcase.html or call the FBI tip line at  415-553-7400.

Today’s charges were brought in connection with the  President’s Financial Fraud Enforcement Task Force.  The task force was established to wage an  aggressive, coordinated and proactive effort to investigate and prosecute  financial crimes.  With more than 20  federal agencies, 94 U.S. Attorneys’ offices and state and local partners, it  is the broadest coalition of law enforcement, investigatory and regulatory  agencies ever assembled to combat fraud.  Since its formation, the task force has made  great strides in facilitating increased investigation and prosecution of  financial crimes; enhancing coordination and cooperation among federal, state  and local authorities; addressing discrimination in the lending and financial  markets and conducting outreach to the public, victims, financial institutions  and other organizations.  Over the past  three fiscal years, the Justice Department has filed nearly 10,000 financial  fraud cases against nearly 15,000 defendants, including more than 2,900  mortgage fraud defendants.  For more  information on the task force, please visit www.StopFraud.gov.

In Search of Effective Ethics & Compliance Programs; By Professor Maurice Stucke, GeyerGorey LLP

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Maurice E. Stucke

University of Tennessee College of Law
December 10, 2013


Abstract: 

The U.S. Sentencing Commission’s Organizational Guidelines for over twenty years have offered firms a significant financial incentive to develop an ethical organizational culture. Nonetheless, corporate crime persists. Too many ethics programs remain ineffective.As this Article explores, the Guidelines’ current approach is not working. The evidence, including sentencing data over the past twenty years, reveals that few firms have effective ethics and compliance programs. Nor is there much hope that the Guidelines’ incentive will induce companies, after the economic crisis, to become more ethical.The problem is not attributable to several assumptions underlying the Guidelines. The empirical research, while still developing, suggests that compliance efforts can be effective, and that effective compliance is attainable. Instead, this Article explores how the Guidelines’ extrinsic, incentive-based approach to compliance does not cure, and likely contributes to, the problem.

 

 

Government Intervenes in False Claims Lawsuit Against Ipc the Hospitalist Co. Inc. Alleging Overbilling of Physician Services

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The government has intervened in a lawsuit against IPC The Hospitalist Co. Inc., and its subsidiaries (IPC), alleging that IPC submitted false claims to federal health care programs, the Justice Department announced today.  IPC, based in North Hollywood, Calif., is one of the largest providers of hospitalist services in the United States, employing physicians and other health care providers who work in more than 1,300 facilities in 28 states.  Hospitalists are physicians who work only in hospitals and other long-term care facilities, overseeing and coordinating inpatient care from admission to discharge.

The lawsuit alleges that IPC physicians sought payment for higher and more expensive levels of medical service than were actually performed – a practice commonly referred to as “upcoding.”  Specifically, the lawsuit alleges that IPC encouraged its physicians to bill at the highest levels regardless of the level of service provided, trained physicians to use higher level codes and encouraged physicians with lower billing levels to “catch up” to their peers.

“We continue to be vigilant in our enforcement efforts to ensure that health care programs funded by the taxpayers pay only for appropriate costs,” said Assistant Attorney General for the Justice Department’s Civil Division Stuart F. Delery.

The lawsuit was filed by Dr. Bijan Oughatiyan, a former IPC physician, under the qui tam, or whistleblower, provisions of the False Claims Act, which permit private parties to sue for false claims on behalf of the government and to share in any recovery.  The Act also allows the government to intervene or take over the lawsuit, as it has done in this case, and to recover three times its damages plus civil penalties.  The government has asked the U.S. District Court in Chicago for 120 days to file its own complaint stating its allegations.

This intervention illustrates the government’s emphasis on combating health care fraud and marks another achievement for the Health Care Fraud Prevention and Enforcement Action Team (HEAT) initiative, which was announced in May 2009 by Attorney General Eric Holder and Health and Human Services Secretary Kathleen Sebelius.  The partnership between the two departments has focused efforts to reduce and prevent Medicare and Medicaid financial fraud through enhanced cooperation.  One of the most powerful tools in this effort is the False Claims Act.  Since January 2009, the Justice Department has recovered a total of more than $17 billion through False Claims Act cases, with more than $12.2 billion of that amount recovered in cases involving fraud against federal health care programs.

The case was investigated by the Commercial Litigation Branch, Civil Division, U.S. Department of Justice and the U.S. Attorney’s Office for the Northern District of Illinois, with assistance from the Department of Health and Human Services Office of Inspector General. The case is captioned United States ex rel. Oughatiyan v. IPC The Hospitalist Company Inc., et al., Civ. No. 09 C 5418 (N.D. Ill.).  The claims asserted against IPC are allegations only; there has been no determination of liability.

How the FTC’s Hertz Antitrust Fix Went Flat – Professor Maurice Stucke; WSJ.com

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How the FTC’s Hertz Antitrust Fix Went Flat
Wall Street Journal
December 8, 2013

Maurice Stucke, a University of Tennessee professor and lawyer with GeyerGorey LLP, said the latest Advantage bankruptcy ought to prompt some soul-searching by the FTC and the Justice Department.

If merger settlements “are going to be business as usual, the agencies need to spend more time examining how their remedies work out over the long haul,” he said. “You would think there could be more safeguards to prevent this from happening.”

FORMER SEA STAR LINE PRESIDENT SENTENCED TO SERVE FIVE YEARS IN PRISON FOR ROLE IN PRICE-FIXING CONSPIRACY INVOLVING COASTAL FREIGHT SERVICES BETWEEN THE CONTINENTAL UNITED STATES AND PUERTO RICO

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WASHINGTON — The former president  of Sea Star Line LLC, a Jacksonville, Fla.-based water freight carrier, was  sentenced to serve five years in prison and to pay a $25,000 criminal fine for  his participation in a conspiracy to fix rates and surcharges for freight  transported by water between the continental United States and Puerto Rico, the  Department of Justice announced today.

Frank Peake was  sentenced today by Judge Daniel R. Dominguez in U.S. District Court for the  District of Puerto Rico in San Juan.  Peake’s  two-week trial took place in January 2013.

“The sentence  imposed today reflects the serious harm these conspirators inflicted on  American consumers, both in the continental United States and in Puerto Rico,” said  Bill Baer, Assistant Attorney General in charge of Department of Justice’s  Antitrust Division.  “The Antitrust  Division will continue to vigorously prosecute executives who collude to fix  prices at the expense of consumers.”

According to court documents and evidence presented at  trial, Peake and his co-conspirators  conspired through meetings and other communications in the continental United  States and Puerto Rico to fix, stabilize and maintain rates and surcharges for  Puerto Rico freight services, to allocate customers of Puerto Rico freight  services between and among the conspirators and to rig bids submitted to  customers of Puerto Rico freight services.   Peake was involved in the conspiracy from at least late 2005 until at  least April 2008.

As a result of the  ongoing investigation, the three largest water freight carriers serving routes  between the continental United States and Puerto Rico, including Peake’s former  employer Sea Star, have pleaded guilty and been ordered to pay more than $46  million in criminal fines for their roles in the conspiracy.  Sea Star pleaded guilty on Dec. 20, 2011, and  was sentenced by Judge Dominguez to pay a $14.2 million criminal fine.  Sea Star transports a variety of cargo  shipments, such as heavy equipment, perishable food items, medicines and  consumer goods, on scheduled ocean voyages between the continental United States  and Puerto Rico.

Peake and five  other individuals have been ordered to serve prison sentences ranging from  seven months to five years.  Additionally,  Thomas Farmer, the former vice president of price and yield management of  Crowley Liner Services, was indicted in March 2013 for  his role in the conspiracy and is scheduled to go to trial in May 2014.

This case is part of an ongoing investigation being conducted by the  Antitrust Division’s National Criminal Enforcement Section and the Defense Criminal  Investigative Service.  Anyone with  information concerning price fixing or other anticompetitive conduct in the  coastal water freight transportation industry is urged to call the Antitrust  Division’s National Criminal Enforcement Section at 202-307-6694.

US Files Suit Against Canton, Ohio-based Tab Construction and Its Owner for Allegedly Defrauding the Historically Underutilized Business Zone Program

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The government has filed a complaint against Canton, Ohio-based TAB Construction Co. Inc. (TAB) and its owner, William E. Richardson III, for allegedly making false statements to the Small Business Administration (SBA) to obtain certification as a Historically Underutilized Business Zone (HUBZone) company, the Justice Department announced today.

 “The HUBZone program is intended to create jobs in areas that historically have had trouble attracting business,” said Assistant Attorney General for the Justice Department’s Civil Division Stuart F. Delery.  “The Justice Department will take strong enforcement action when companies obtain contracts to which they are not entitled.”

The government alleges that TAB used its fraudulently procured HUBZone certification to obtain four U.S. Army Corps of Engineers’ construction contracts worth millions of dollars.  Each of those contracts had been set aside for qualified HUBZone companies.  The government’s complaint asserts claims against TAB and Richardson under the False Claims Act and the Financial Institutions Reform, Recovery and Enforcement Act of 1989.

Allegedly, Richardson originally applied to the HUBZone program in 2000 by claiming that TAB’s principal office was located in a designated HUBZone when no TAB employees worked out of the HUBZone office, and TAB actually was located in a non-HUBZone.  Even though Richardson told the SBA that TAB was located in a HUBZone, Richardson consistently used his non-HUBZone address in conducting TAB’s other business affairs, at one point even stating under oath in private litigation that TAB’s office was located in a non-HUBZone.  In 2006, Richardson allegedly applied for re-certification to the HUBZone program, again falsely stating that eight employees worked in the designated HUBZone.  The government alleges that just six weeks after Richardson re-certified its eligibility with the SBA, TAB completed an affidavit in an unrelated matter, which stated that TAB’s principal office was located in a non-HUBZone.

Under the HUBZone program, companies that maintain their principal office in a designated HUBZone, and meet certain other requirements, can apply to the SBA for certification as a HUBZone small business company.  HUBZone companies can then use this certification when bidding on government contracts.  In certain cases, government agencies will restrict competition for a contract to HUBZone-certified companies.

“We will not tolerate fraud in the HUBZone or any other SBA program,” said SBA Inspector General Peggy E. Gustafson.  “With our interagency partners, this office will continue to pursue those who defraud the government by lying to gain access to federal set-aside contracts.”

“SBA’s contracting programs, including the HUBZone program, provide small businesses with the opportunity to grow and create jobs,” said SBA General Counsel Sara D. Lipscomb.  “SBA has no tolerance for waste, fraud or abuse in any government contracting program and is committed to working with our federal partners to ensure the benefits of these programs flow to the intended recipients.”

The government filed its complaint in two consolidated lawsuits filed under the qui tam, or whistleblower, provisions of the False Claims Act.  Under the Act, a private citizen can sue on behalf of the government and share in any recovery.  The government also is entitled to intervene in the lawsuit, as it has done in this case.

This matter was handled by the Commercial Litigation Branch of the Justice Department’s Civil Division in conjunction with the Small Business Administration’s Office of Inspector General and Office of General Counsel and the Defense Criminal Investigative Service.

The consolidated civil cases are U.S. ex rel. Roy. J. Fairbrother Jr. and Louis Petit v. TAB Construction Co. Inc., et al., No. 5:11-cv-1432 (N.D. Ohio) and U.S. ex rel. Patricia Hopson and Vince Pavkov v. TAB Construction Co. Inc., No. 5:12-cv-135 (N.D. Ohio).  The claims asserted against TAB and Richardson are allegations only, and there has been no determination of liability.

Miami Home Health Company Owner and Recruiter Sentenced for Role in $48 Million Health Care Fraud Scheme

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A patient recruiter of a Miami health care company was sentenced to serve 108 months in prison today for his participation in a $48 million home health Medicare fraud scheme.
Acting Assistant Attorney General Mythili Raman of the Justice Department’s Criminal Division, U.S. Attorney Wifredo A. Ferrer of the Southern District of Florida, Special Agent in Charge Michael B. Steinbach of the FBI’s Miami Field Office and Special Agent in Charge Christopher B. Dennis of the U.S. Department of Health and Human Services Office of Inspector General (HHS-OIG) Office of Investigations Miami Office made the announcement.
Emilio Amador, 46, was sentenced by U.S. District Judge Federico A. Moreno in the Southern District of Florida.   In addition to his prison term, Amador was sentenced to serve three years of supervised release and ordered to pay $24 million in restitution, jointly and severally with co-defendants.
In September 2013, Amador pleaded guilty before Judge Moreno to one count of conspiring to receive health care kickbacks and two counts of receiving health care kickbacks.
According to court documents, Amador was a patient recruiter who worked for Caring Nurse Home Health Care Corp., a Miami home health care agency that purported to provide home health and therapy services to Medicare beneficiaries.
From approximately January 2006 through June 2011, Amador would recruit patients for Caring Nurse, and in doing so would solicit and receive kickbacks and bribes from the owners and operators of Caring Nurse in return for allowing Caring Nurse to bill the Medicare program on behalf of the patients Amador had recruited.   These Medicare beneficiaries were billed for home health care and therapy services that were medically unnecessary and/or not provided.
According to court documents, Amador also pleaded guilty to his involvement with fraudulent billings for Nation’s Best Care Home Health Corp. as relevant conduct.   Amador was the owner, operator and president of Nation’s Best.   The fraudulent billings for Nation’s Best totaled approximately $30 million.
In a related case, on Feb. 27, 2013, Rogelio Rodriguez, 44, and Raymond Aday, 49, the owners and operators of Caring Nurse and Good Quality, were sentenced to serve 108 and 51 months in prison, respectively.  The sentencings followed their December 2012 guilty pleas to one count each of conspiracy to commit health care fraud charged in an October 2012 indictment, which alleged that from approximately January 2006 through June 2011, Caring Nurse and Good Quality submitted approximately $48 million in claims for home health services that were not medically necessary and/or not provided.  Medicare paid approximately $33 million for those fraudulent claims.
The case was investigated by the FBI and HHS-OIG and was brought as part of the Medicare Fraud Strike Force, under the supervision of the Criminal Division’s Fraud Section and the U.S. Attorney’s Office for the Southern District of Florida.   This case is being prosecuted by Assistant Chief Joseph S. Beemsterboer of the Criminal Division’s Fraud Section.
Since their inception in March 2007, Medicare Fraud Strike Force operations in nine locations have charged more than 1,700 defendants who collectively have falsely billed the Medicare program for more than $5.5 billion.   In addition, the HHS Centers for Medicare and Medicaid Services, working in conjunction with the HHS-OIG, are taking steps to increase accountability and decrease the presence of fraudulent providers.

Three Patient Recruiters for Miami Home Health Company Plead Guilty for Roles in $48 Million Fraud Scheme

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Three patient recruiters for a Miami health care company pleaded guilty today for their participation in a $48 million home health Medicare fraud scheme.
Acting Assistant Attorney General Mythili Raman of the Justice Department’s Criminal Division, U.S. Attorney Wifredo A. Ferrer of the Southern District of Florida, Special Agent in Charge Michael B. Steinbach of the FBI’s Miami Field Office, and Special Agent in Charge Christopher B. Dennis of the U.S. Department of Health and Human Services Office of Inspector General (HHS-OIG) Office of Investigations Miami Office made the announcement.
Miami residents Marianela Martinez, 45; Omar Hernandez, 48; and Celia Santovenia, 49, pleaded guilty before U.S. District Judge Donald L. Graham in the Southern District of Florida to one count each of conspiracy to receive health care kickbacks.   Sentencing has been scheduled for Feb. 11, 2014.
According to court documents, Martinez, Hernandez and Santovenia were patient recruiters who worked for Caring Nurse Home Health Care Corp., and Santovenia also worked for Good Quality Home Health Care Inc.   Caring Nurse and Good Quality were Miami home health care agencies that purported to provide home health and therapy services to Medicare beneficiaries.
From approximately January 2006 through June 2011, the defendants would recruit patients for Caring Nurse and/or Good Quality and would solicit and receive kickbacks and bribes from the owners and operators of Caring Nurse and/or Good Quality in return for allowing the agency to bill the Medicare program on behalf of the recruited patients.   These Medicare beneficiaries were billed for home health care and therapy services that were medically unnecessary and/or not provided.
In a related case, on Feb. 27, 2013, Rogelio Rodriguez, 44, and Raymond Aday, 49, the owners and operators of Caring Nurse and Good Quality, were sentenced to serve 108 and 51 months in prison, respectively.  The sentencings followed their December 2012 guilty pleas to one count each of conspiracy to commit health care fraud charged in an October 2012 indictment, which alleged that from approximately January 2006 through June 2011, Caring Nurse and Good Quality submitted approximately $48 million in claims for home health services that were not medically necessary and/or not provided.  Medicare paid approximately $33 million for those fraudulent claims.
The case was investigated by the FBI and HHS-OIG and was brought as part of the Medicare Fraud Strike Force, under supervision of the Criminal Division’s Fraud Section and the U.S. Attorney’s Office for the Southern District of Florida.  This case is being prosecuted by Assistant Chief Joseph S. Beemsterboer of the Criminal Division’s Fraud Section.
Since their inception in March 2007, Medicare Fraud Strike Force operations in nine locations have charged more than 1,700 defendants who collectively have falsely billed the Medicare program for more than $5.5 billion.  In addition, the HHS Centers for Medicare and Medicaid Services, working in conjunction with the HHS-OIG, are taking steps to increase accountability and decrease the presence of fraudulent providers.