Amtrak OIG-supported investigation leads to charges in $618 million substance abuse treatment fraud scheme

August 07, 2020 |  Investigations Press Release

For Immediate Release

August 7, 2020


PALM BEACH COUNTY, Fla. — A Florida doctor was charged with conspiring to commit health care fraud and wire fraud on July 31, 2020, for allegedly participating in a years-long scheme in which patients seeking care for drug and/or alcohol addiction were fraudulently billed for tests and treatments.


According to court documents, Michael J. Ligotti, D.O., 46, of Delray Beach, owned and operated a private medical clinic, Whole Health, which offered addiction treatment, family care, and urgent care. From May 2011 through March 2020, Ligotti allegedly played a central role in the massive fraud scheme in which Medicare and insurance companies, to include Amtrak’s, were billed approximately $681 million for laboratory testing claims and other services. Amtrak’s health care plan was billed more than $1.2 million and paid out more than $365,000. According to the complaint, Ligotti allegedly served as “medical director” for more than 50 addiction treatment facilities or sober homes and signed over 136 standing orders authorizing medically unnecessary and duplicative urinalysis tests. In exchange for the authorizations, the other facilities and sober homes were allegedly required to bring their patients to Whole Health, allowing Ligotti and Whole Health to bill medical treatments for these patients at his own clinic for false and fraudulent treatments and testing. In cases where urinalysis tests authorized by Ligotti were conducted at outside laboratories, the labs would also bill insurance companies and some labs paid kickbacks to the treatment facilities and sober homes.


The complaint further alleged that Ligotti authorized and conducted bodily fluid tests for revenue-generation and did not use the test results in patient treatments. Ligotti also allegedly billed for psychiatric services and therapy sessions that never happened and that he and his staff were not qualified to conduct. Finally, the complaint alleged that Ligotti improperly prescribed controlled substances to patients.


Ligotti was charged with conspiracy to commit health care fraud and wire fraud.


In addition to Amtrak OIG, the case was investigated by the FBI’s Palm Beach County RA, the IRS-Criminal Investigation, Florida Division of Investigative and Forensic Service, the Drug Enforcement Administration, and the Palm Beach County State Attorney’s Office.


An indictment is merely an allegation and the defendants are presumed innocent until proven guilty beyond a reasonable doubt in a court of law.


More information is available in the U.S. Department of Justice press release:


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