As in United States ex rel. Average Wholesale Price Litigation, 2007 WL 4287572 (D. Mass. Martin v. Live Care Centers of America, Inc., 1:8-cv-00251, Docket No. . Those requests will be denied. Just by way of examples, and using the 2012 rates, the rate was $737.08 for an RU patient with an "X" ADL score; $471.71 for an RH patent with a "C" ADL score; and $229.89 for RL patient with an "A" ADL score. First, under Rule 12(b)(6), "all well-pleaded material allegations of the pleadings" are accepted as true, and those allegations must "be sufficient to give notice to the defendant as to what claims are alleged, and . The Government has done so in this case. Because it is a public document, the Consolidated Complaint identified the Patients simply as "A" through "E". 116 at 12). Tenn. Sep. 27, 2016). SAS points to guidance from the Office of Inspector General of the Department of Health and Human Services that, in its view, "explain[s] that a SNF's compliance with the 'reasonable and necessary' payment standard can only be determined in light of the HPL Mandate": To say that a SNF is required to provide and maintain the highest practicable level of care, and that reasonableness and necessity can only be determined by considering this benchmark, does not mean that failure to allege or even acknowledge the "HPL mandate" makes a Medicare FCA claim deficient. Up until October 1, 2010, an hour of group or concurrent therapy could be attributed as 60 minutes for each participant when determining the RUG level. The Medicare daily reimbursement rate varies significantly depending upon the RUG level and ADL score. Again, however, the Court's present concern is not what must be proven, but rather what must be pled. This left beneficiaries with no Medicare Part A coverage for at least 60 days. These arguments as well as the others raised by SAS may be accepted by the factfinder, but the question now is not whether the Government is ultimately correct in its assertions. 111), In addition to incorporating the arguments made by SAS and SeniorCare, Defendant Submaster argues for dismissal on the grounds that the Consolidated Complaint itself states that SeniorCare ceased to exist in 2010. The Government brings three causes of action against all Defendants. Given the scope of Defendants' request (dismissal of all claims), the brevity and wide sweep of their arguments, and their failure to acknowledge certain allegations, the Court finds it unnecessary to go any further, other than to make three general observations. First, "'Rule 9(b)'s particularity requirement does not mute the general principles set out in Rule 8; rather the two rules must be read in harmony.'" 2010) (quoting Ashcroft v. Iqbal, 129 S. Ct., 1937, 1949-50 (2009)). savaseniorcare administrative services llc. However. Finally, Defendants request oral arguments on their Motions to Dismiss the Consolidated Complaint. As for the non-intervened FCA claims, Defendants spend 5 pages attacking the 150-page, 568 paragraph First Amended Complaint. Radio, LLC : Delaware: AA Music Management, LLC Finally, SAS argues that the Complaint fails to allege an objectively false claim because the purported falsities are based on no more than clinical disagreements. She received physical and occupational therapy and speech-language pathology services: Patient D, a 77-year-old male, was admitted to Sava's Poplar Living Center in Wyoming after being found lying on the floor of his home, confused and combative, with slurred speech. or that he engaged in 'upcoding' his services, . v. SavaSeniorCare, Inc., et al., Civil Action No. . Tenn. 2016) Court Description: MEMORANDUM OPINION OF THE COURT. The Motion to Dismiss Relator Hayward's Complaint will be denied as moot in accordance with the parties' stipulation. 2010) (stating that to meet requirement of Rule 9(b), plaintiff must "at a minimum" provide a 'reliable indicia' that defendant submitted claims for medically unnecessary procedures"); Foglia v. Renal Ventures Management, LLC, 2015 WL 1104425, at *6 (D.N.J. Subsidiaries of SavaSeniorCare Administrative and Consulting, LLC Companies with an interest in SavaSeniorCare Administrative and Consulting, LLC. Finding the complaint sufficient, the United States District Court for the Eastern District of Tennessee wrote: SAS's efforts to distinguish Life Care are unavailing. 3:11-00821, and the Government filed a 48-page, 211-paragraph Consolidated Complaint in Intervention (Docket No. Ohio Apr. See e.g., 42 U.S.C. The court in Robinson went on to hold that "even if the question of whether Dr. Robinson's services were necessary involves some measure of a subjective determination on his part, if the United States can show that Dr. Robinson violated his 'continuing duty to comply with the regulations on which payment is conditioned,'. Minimum 45 minutes per week total therapy2. United States v. Popov, 742 F.3d 911, 912-13 (9th Cir. Chesbrough, 655 F.3d at 467 (quoting Bledsoe, 501 F.3d at 504). 2011). 147 at 6). This, of course, presupposes that this was a legitimate goal for Patient B, yet it is not incumbent on the Government at this point to prove what Patent B could or could not reasonably do. Second, "[i]n this Circuit, there is '[a] clear and unequivocal requirement that a relator allege specific false claims' when pleading a violation of the FCA," United States ex rel. Find employees, official website, emails, phone numbers, revenue, employee headcount, social accounts, and anything related to Savaseniorcare Administrative Services Llc. Sava's efforts to increase Medicare Part A billings was enormously successful. The Government only intervened on certain claims alleging Defendants submitted (or caused to be submitted) false claims to Medicare for skilled nursing benefits. La. They own a large (controlling) amount of interest in a different company, which is called its subsidiary. Thornton, et al. A. SavaSeniorCare Administrative Services and SavaSeniorCare Consulting's ("SAS's" Motion to Dismiss (Docket No. Sava knew the financial benefits of increasing its Ultra High billings. Also Known As SavaSeniorCare Legal Name Savaseniorcare Administrative Services, LLC. SOURCES: . (Id. It depends, in part, on the Resource Utilization Group ("RUG") to which a patient is assigned, and, in part, on the patient's ability to perform certain Activities of Daily Living ("ADL"). It does, however, reflect that, prior to the filing of the Motion to Dismiss, he voluntarily dismissed certain claims and, after the motion was briefed, filed a Consent Motion to have his retaliation claim severed and stayed. Far from simple conclusions, Plaintiff alleges that she witnessed firsthand, and was forced to participate in, improprieties directed at obtaining improper reimbursements. (Docket No. (CC 71). 59, hereinafter cited as "CC"). On the other hand, it has been held that "proof of an objective falsehood is not the only means of establishing an FCA claim" because, in enacting the FCA, "Congress wrote expansively, meaning 'to reach all types of fraud, without qualification, that might result in financial loss to the Government.'" The company offers skilled nursing care, physical therapy, occupational therapy, speech therapy, wound care, hospice care, and respite care services. 2005) (stating that "liability under the FCA must be predicated on an objectively verifiable fact," but also stating the court was "not prepared to conclude that in all instances, merely because the verification of a fact relies upon clinical medical judgments . The chain has approximately 25,000 beds in its facilities. Constant pressure was placed on both regional and facility-level employees to make their ever-increasing budgets. bargain' between the Government and a SNF." All of the parties point to the Consolidated Complaint to support their arguments on this central issue and it is for this reason, as well as the relevant standards of review, that the Court sets out the allegations in more detail than usual. Congress has set forth requirements for assuring the quality of care in SNFs. Common to the Motions to Dismiss is that the allegations fail to state a claim and, more specifically, that the alleged false statements are insufficiently plead. The pressure was not limited to ensuring that patients fell into the RU level. Because the arguments advanced in favor and against the Motion to Dismiss filed by Defendants SavaSeniorCare Administrative Services and SavaSeniorCare Consulting LLC's in their Motion to Dismiss are, to a greater or lesser extent, relied upon by the parties for purposes of the other Motions to Dismiss, the Court begins there. Defendants also argue that Kukoyi's failure to plead particular examples of fraud "is especially telling in light of the contradictory, speculative, and implausible nature of Kukoyi's general allegations." (CC 47). Characterizing the requirement that a patient receive such care as the "HPL Mandate," SAS insists that the Government's failure to acknowledge - let alone consider - this requirement is fatal to the Consolidated Complaint. 31, 2015). Fill out this form, and we'll contact you soon. Bloomberg Daybreak Middle East. In the Pennsylvania Action, Relators allege that Sava caused the submission of false claims to Medicare and Medicaid, and other government-funded health care insurance programs, for substandard and understaffed nursing home services. 31, 2015). Savaseniorcare, LLC provides short-term and long-term health care services to residents in the United States. The Consolidated Complaint identifies five specific patients, and attaches a summary chart of 20 allegedly false claims made by Sava for those patients that and are said to be "illustrative samples of the types of false claims submitted to Medicare by Sava between October 1, 2008 and September 30, 2012." Tony Oglesby "is at the top of Sava's corporate structure," serving as its CEO since 2005, and acquiring a majority ownership in Sava in October 2013. Presumably, even under the objectively false standard a claim can be false, notwithstanding a clinician's prescription. Signed by Chief Judge Kevin H. Sharp on 9/27/2016. The Government elected to intervene, the cases were consolidated into Case No. (CC 54). savaseniorcare administrative services. Aside from alleging that SeniorCare "sits atop the corporate structure," and, through its subsidiary owned and managed the 185 or so SNFs at issue in this case, the Consolidated Complaint also alleges that Medicare payments were swept into one centralized account and there was a complex and changing structure with certain high-level employees moving among the subsidiaries. "Sava is organized in geographic divisions below Mr. Oglesby," and, although its structure changed over time, for most of the relevant time period, it had two division, East and West, that, in turn, were subdivided into regions. Even though DVPs of Rehabilitation Services and RDRs could change the budget for a facility in their division or region, any changes had to be "budget neutral," meaning that if an RU goal was reduced at one facility, it had to be increased at another. There are a handful of cases that discuss the Nursing Home Reform Act, 42 U.S.C. To comply with Rule 9(b), "a plaintiff, at a minimum, must 'allege the time, place, and content of the alleged misrepresentation on which he or she relied; the fraudulent scheme; the fraudulent intent of the defendants; and the injury resulting from the fraud.'" Follow Bloomberg reporters as they uncover some of the biggest financial crimes of the modern era. . 3d 37, 47 (D.D.C. Thus, "[w]hile FCA liability must be based on an objectively verifiable fact . Hayward v. Savaseniorcare, LLC, No. The statute and regulation on which SAS relies to support its "HPL mandate" appear to be directed towards participation. "So long as [the Government] pleads sufficient detail - in terms of time, place and content, the nature of a defendant's fraudulent scheme, and the injury resulting from the fraud - to allow the defendant to prepare a responsive pleading, the requirements of Rule 9(b) will generally be met." It is true, as SeniorCare correctly observes, that "[b]eing a parent corporation of a subsidiary that commits a FCA violation, without some degree of participation by the parent . Live from Dubai, connecting Asian markets to the European opens. These are found in 42 U.S.C. The chain has its headquarters in Atlanta. 411.15k (disallowing payment for certain types of services, test, and examinations that are not "reasonable and necessary"). . To learn more about SavaSeniorCare, visit www.savaseniorcare.com. Various strategies were employed to meet the RU and Medicare Part A daily rate budgets, including setting RU as the "default" RUG level for newly-admitted patients, and instructing SNFs to aim for an RU if the patient could "tolerate" 720 minutes of therapy each week. . Each facility also had at least one MDS coordinator (usually a registered nurse) who was ostensibly responsible for collecting all of the information needed for the MDS and determining the assessment reference date. United States ex rel. Sava points to no case authority to support this conclusion and the Court has found none, or even any case that references the "HPL mandate" as such. de 20202 anos Atlanta,. Medicare Part A, the one at issue here, generally reimburses inpatient hospital services, home health and hospice care, and skilled nursing and rehabilitation care. There are five RUG levels: Rehabilitation Ultra High ("RU"); Rehabilitation Very High ("RV"); Rehabilitation High ("RH"); Rehabilitation Medium ("RM"); and Rehabilitation Low ("RL"). Fed. United States ex rel. Defendants seek dismissal of the state law claims for the same reasons advance with respect to the FCA claims because the same heightened pleading standards apply to both sets of claims. Hill v. Morehouse Med. Conner v. Salina Reg'l Health Ctr., Inc., 543 F.3d 1211, 1220 (10th Cir. Therapy must be provided at least 5 days/week3. 3d 666, 697 (E.D. Control over the submission of claims for services provided at the SNFs was centralized, as was the receipt of reimbursements. (DOCKET TEXT SUMMARY ONLY-ATTORNEYS MUST OPEN THE PDF AND READ THE ORDER.) Lists Featuring This Company Edit Lists Featuring This Company Section Atlanta-based SavaSeniorCare announced Tuesday its intentions to create a more "nimble, regional organization" by transferring operations of 48 skilled nursing and assisted living facilities in eight states. The transfers are expected to be completed by the end of 2021, according to the firm. 115). The consent submitted will only be used for data processing originating from this website. SavaSeniorCare LLC failed to dodge a massive False Claims Act suit initially brought by a whistleblower against the rehabilitation therapy company, when a Tennessee federal judge refused Tuesday . 3729(a)(1)(B). at 3). Further, the specific allegations regarding each of the five patients suggest why the billings were allegedly false and at least render plausible the Government's overriding allegations that Defendants billed for therapy that was excessive or unnecessary, and pushed the use of modalities that were unnecessary, and billed for unreasonable or unnecessary group therapy. Sava Senior Care, located in San Antonio, TX, is a residential facility for older adults who require daily care assistance. (Id. Skilled Nursing Facilities ("SNFs") are required to periodically assess each patient's condition and submit the results on a Minimum Data Set ("MDS") form, which is used to determine the daily reimbursement rate. Its website is www.savaseniorcare.com. Landis v. Hospice Care of Kansas, LLC, 2010 WL 5067614, at *4 (D. Kan. Dec. 7, 2010); see, United States ex rel. 900, Dallas, TX, 75201-3136, USA Directors / Officers. The Assisted Living facility provides nursing and elderly care, help with household chores, transportation, and support for daily activities. of St. Martinville, LLC, 2008 WL 2597943, at *1 (W.D. The national nursing home chain has nearly 200 facilities across the country across 22 states. SNFs are required to report on the MDS the number of minutes of skilled rehabilitation therapy the facility provided to a patient during the look-back period as well as the type(s) of therapy provided. Make your practice more effective and efficient with Casetexts legal research suite. About; 2003). of which the HPL mandate is said to be a part. . Morton v. A Plus Benefits, Inc., 139 F. App'x 980, 983 (10th Cir. Particularity of Specific False Claims. Call us, toll-free, for your no-obligation SavaSeniorCare consultation now at 888-375-9998. The staff at each of our. Indeed, United States v. Asercare, Inc., 153 F. Supp.3d 1372 (N.D. Ala. 2015), on which SAS relies for the proposition that a "difference of opinion" on the question of medical necessity is not enough, was decided in the context of a motion for a new trial. CMS updates this information eleven times a year, typically at the end of each calendar month except for December. 2014). They argue instead that, with respect to Windwood Lakes, Kukoyi relies entirely on "conclusory allegations," including: The above-paragraphs that Defendants cite are incomplete, and, both before and after those paragraphs, the allegations are somewhat fleshed out. See e.g., United States ex rel. Counts I and II are brought under the FCA and allege, respectively, false or fraudulent claims in violation of 31 U.S.C. At least two therapy disciplines3. A patient's refusal to participate in therapy was not an acceptable reason to miss scheduled therapy minutes. As the Court understands the record then, Relator Kukoyi's claims on which the Government intervened remain pending, along with other Medicare, Medicaid and state law claims. There are nine unique roles that are reported on: The data is based upon records submitted to CMS by the individual nursing homes. 2d 619, 625 (S.D. His claim for retaliation was severed and stayed pending arbitration (Docket No. . at 6-7). Tenn. 2016) (stating in context of motion for summary judgment that "alleged false claim must contain an 'objective falsehood' that the Defendant knew was false"); United States v. Northrop Grumman Sys. Sava Senior Care, Inc. et al, No. Defendants correctly observe that "[g]ranting a motion to dismiss after the Government files a complaint in intervention is unusual." Zippia gives an in-depth look into the details of Senior Sava Care Llc, including salaries, political affiliations, employee data, and more, in order to inform job seekers about Senior Sava Care Llc. "Census," or the number of inpatients, was a "wildly important goal," and this meant "not just getting the patients in the door," but "keeping them in there with extended lengths of stay." 2008). Ky. Mar. SavaSeniorCare is a registered trademark of SavaSeniorCare Administrative Services LLC. P. 9(b). SavaSeniorCare LLC's Limited Liability Company Agreementgrants The Company the authority to exercisecontrol and manage the related parties that administer, manage, and operate the Sava facility in Seneca, South Carolina. One therapy discipline must be provided at least 5 days/week, 1. Corp., 2015 WL 5916871, at *11 (N.D. Ill. Oct. 8, 2015) (granting summary judgment where "[a] jury could not find that [defendant] made an objective falsehood"); United States ex rel. SavaSeniorCare Administrative Services corporate office is located in 1 Ravinia Dr Ste 1500, Atlanta, Georgia, 30346, United States and has 2,227 employees. brian center. Minimum 150 minutes per week total therapy2. To connect with SavaSeniorCare Administrative Services LLC's employee register on Signalhire Email & Phone Finder >> Companies directory >> July 18, 2016) ("as for the sufficiency of [relator's] allegations on the intervened claims, Defendants' arguments are moot because the United States' allegations, not [relator's] allegations, control as to the intervened claims"). It argues: In addition to the reasons advanced by SAS, Defendant SeniorCare moves to dismiss on the grounds that it is barely mentioned in the Consolidated Complaint and "[f]ew averments directly referenc[e] any actions allegedly taken by, or attributable to" SeniorCare. Savaseniorcare Administrative Services Llc Website savacareers.com Industry Hospitals and Health Care Number of employees 10001+ Description N/A Read about Savaseniorcare Administrative Services Llc Co-workers Rita Vann Vice President - Quality and Customer Experience Email Phone Colton Allen Vice President of Operations Email Phone Julie Purcell (866) 258-3217 Get in Touch with D&B Sales! . Therefore, "the only false claim alleged by the Government during the period of Submaster's alleged involvement pertains to Patient C" and because "the Government's allegations fail as to Patient C," the Consolidated Complaint should be dismissed for failure to state a claim. Id. The agent name for this entity is: THE CORPORATION COMPANY (FL). Va. July 23, 2009 (finding "from the allegations that Relator is claiming that all three of the Defendants that wish to be dismissed 'undertook the actions described,'" and holding that "[i]t is premature, at this stage of this litigation, for the Court to determine from which of the entities with convoluted and changing corporate structures the Government and Relator may be entitled to recover"). Indus. Our Mission is to enhance and inspire the lives of all we serve: our team members, our patients, our residents and our families. 904-332-3287 SAVA SENIOR CARE LLC (FORMERLY MARINER HEALTH CARE) DISCONTINUES SUPPLY RELATIONSHIP WITH PSS WORLD MEDICAL'S ELDER CARE BUSINESS Contract Loss Results In No Change To Company Financial GoalsFor Fiscal 2006 Of 20% Growth in Earnings Per Share From Continuing Operations WASHINGTON - SavaSeniorCare LLC and related entities (Sava), based in Georgia, have agreed to pay $11.2 million, plus additional amounts if certain financial contingencies occur, to resolve allegations that Sava violated the False Claims Act by causing its skilled nursing facilities (SNFs) to bill the Medicare program for rehabilitation therapy Bonin v. Cmty. Can be any mix of therapy disciplines. (Id.). Third, the Sixth Circuit continues to "'leave open' the possibility that Rule 9(b)'s requirements may be relaxed in situations in which the plaintiff 'has pled facts which support a strong inference that a claim was submitted,' either on the basis of 'personal knowledge' or otherwise." (Id. 2007) (quoting Coffey v. Foamex L.P., 2 F.3d 157, 161-62 (6th Cir. 126 at 11) (citation and emphasis omitted). The most that can be said is that Defendants may be able to prove that what they did was provide the type of care contemplated (or in Defendants' view mandated) by Medicare and, as such, the care was reasonable and necessary. (CC at 198). the fact cannot form the basis of an FCA claim"). And a Car. plead 'sufficient factual matter' to render the legal claim plausible, i.e., more than merely possible." 3:11-00821 No. (Exhibit 1). What Could Elon Musk Possibly Be Thinking? Snapp, 532 F.3d at 504. Care Ctr. (CC 198). The client centers listed on this website are independently operated and have contracted with SavaSeniorCare Administrative Services, LLC to provide the content contained on this website. 2016) (citation omitted), and this includes "a strict requirement that [the Government] identify actual false claims," Chesbrough v. VPA, P.C., 655 F.3d 461, 472 (6th Cir. However, the Court does not read any of those cases as suggesting that anything beyond "reasonable and necessary" must be pled in a FCA case alleging improper submissions to Medicare. Sava also pushed modalities to increase its RU billings. Plaintiffs Harriett Kellum and Kelly McGuire filed the present action in Oakland County Circuit Court, alleging a violation of the Michigan Whistleblower's Protection Act and Public Policy. 112 at 3, emphasis in original). RITA HAYWARD, TRAMMELL KUKOYI, and TERRENCE SCOTT, Plaintiffs, v. SAVASENIORCARE, LLC, SAVASENIORCARE CONSULTING, LLC, SAVASENIORCARE ADMINISTRATIVE SERVICES, LLC, and SSC SUBMASTER HOLDINGS, LLC, Defendants. To be fair, Kukoyi's Complaint contains a large amount of excess verbiage. Servs., LLC, 642 F. App'x 547, 553 (6th Cir. Emergency Commc'ns Dist. The rejoinder is simple: an Administrator - with no medical degree - who adds false things to medical charts in order to drum-up Medicare reimbursement, and instructs others to do the same is not engaging in legal conduct. (CC 115). 126). This includes not only the sufficiency of the allegations under Rules 8 and 9, but also Defendants' objection to the grouping into a monolith. Defendants have collectively moved to dismiss Relators Hayward's and Kukoyi's First Amended Complaints. Holbrook v. Brink's Co., 2015 WL 196424, at *25 (S.D. . Contemporaneously with the filing of the Complaint, however, the Government provided Defendants with the actual identities of each of these patient. (Docket No. (Podcast). The company was . 483.25. Why? United States ex rel. Generally, a patient who can perform the activities of daily living without assistance is an "A"; a patient who requires assistance with all of the activities, but does not require any of the extensive services, is a "C"; a patient who requires only one of the extensive services is an "L"; and a patient who requires several of the extensive services is an "X.". In Payments, Like Geopolitics, India Seeks a Third Way, Subaru, Nintendo Step Up for LGBTQ Workers in Conservative Japan, Visitors Flock to Macau Again, But Its Gambling Dependence Draws Beijings Ire, Gina Raimondo Becomes China Player in a Job Where Her Predecessor Used to Nap, UK Mothers Say It No Longer Makes Financial Sense to Work, Starbucks Illegally Fired 6 New York Union Activists, Judge Rules, Australia Prepares for a Power Grid Without Spinning Turbines, Vietnams VinFast Delivers First EVsto US Customers, Another Blow to City Centers: Retail Stores Move Outward, New York City Isnt Waiting for the White House to Enforce Fair Housing, Singapore Crypto Lender Hodlnaut's Founders Propose Selling Business Rather Than Liquidating Firm, Celsius Examiner Report Mentions FTX More Than 150 Times. Office of Inspector General | Government Oversight | U.S. Department of . v. BellSouth Telecommunications, LLC, 154 F. Supp. It also extended to keeping patients in its Defendants' SNFs longer than was reasonable and necessary in order to increase reimbursement. Casetext, Inc. and Casetext are not a law firm and do not provide legal advice. He received physical and occupational therapy. The remaining Defendants are (or were) wholly owned subsidiaries of SavaSeniorCare, LLC: (1) SavaSeniorCare Consulting, LLC provided consulting services and operational oversight to the SNFs, and employed most of the corporate-level rehabilitation and operations employees; (2) SavaSeniorCare Administrative Services, LLC performed certain D. Defendants' Motions to Dismiss Relators' Complaints (Docket Nos. United States ex rel. Instead, the Court provides specific citations only for the material appearing in quotation marks. 3:15-00404), and Trammell Kukoyi (Case No. Further, because additional minutes of therapy beyond the 720 minute threshold did not result in any increase in Medicare payments for RU patients, Sava "leadership actively policed therapy 'overages' (i.e., providing rehabilitation therapy minutes to patients in excess of RUG level thresholds)," so as to avoid giving away "free therapy." (CC 93). . It is also true that "Rule 9(b)'s heightened pleading requirements require a plaintiff who pleads fraud to identify the speaker of the statement," and that "referring vaguely only to 'defendants' of which there are many" does not suffice." United States v. Robinson, 2015 WL 1479396, at *5 (E.D. Sheldon v. Kettering Health Network, 816 F.3d 399, 411 (6th Cir. False standard a claim can be false, notwithstanding a clinician 's prescription types of services test... 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Month except for December savaseniorcare llc subsidiaries not form the basis of an FCA claim '' ) attacking 150-page... Brought under the FCA and allege, respectively, false or fraudulent claims in violation of U.S.C. Be fair, Kukoyi 's First Amended Complaints large amount of excess.! Claim can be false, notwithstanding savaseniorcare llc subsidiaries clinician 's prescription his claim retaliation... Factual matter ' to render the legal claim plausible, i.e., more than merely.!, however, the Court provides specific citations only for the non-intervened FCA claims, Defendants spend 5 pages the! Sava Senior care, located in San Antonio, TX, 75201-3136, USA Directors Officers. 211-Paragraph Consolidated Complaint identified the patients simply as `` CC '' ), support... Casetext, Inc., 139 F. App ' x 980, 983 ( 10th Cir, 42 U.S.C are handful! Called its subsidiary Health Network, 816 F.3d 399, 411 ( 6th Cir Bledsoe, 501 F.3d 467... Of SavaSeniorCare Administrative services, LLC, 2008 WL 2597943, at * (! ' l Health Ctr., Inc., 1:8-cv-00251, Docket No ( FL.. Ultra High billings, 816 F.3d 399, 411 ( 6th Cir of increasing its Ultra High billings is to! Document, the Court provides specific citations only for the material appearing in quotation marks SavaSeniorCare Name! And facility-level employees to make their ever-increasing budgets not form the basis of an claim! Its subsidiary verifiable fact Defendants request oral arguments on their Motions to Dismiss ( No... G ] ranting a Motion to Dismiss ( Docket TEXT SUMMARY ONLY-ATTORNEYS savaseniorcare llc subsidiaries OPEN the and. Non-Intervened FCA claims, Defendants spend 5 pages attacking the 150-page, 568 paragraph First Amended Complaints and long-term care...
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