Business ProfileforWhole Health, L.L.C.

UPDATE As of January 9, 2023:

A Florida doctor was sentenced to 20 years in prison for engaging in a massive multi-year scheme to bill health care benefit programs for fraudulent tests and treatments for vulnerable patients seeking treatment for drug and/or alcohol addiction. This case was brought as part of the Department of Justice’s Sober Homes Initiative.

According to court documents, Michael J. Ligotti, D.O., 48, of Delray Beach, served as Medical Director or Authorizing Physician for over 50 sober homes, substance abuse treatment facilities, and clinical testing laboratories in the Palm Beach County area, often signing standing orders for expensive, medically unnecessary urine drug tests for patients at various addiction treatment facilities. These facilities routinely sent patients’ urine specimens to clinical testing laboratories, which then billed health care benefit programs for unnecessary urine drug tests, often thousands of dollars for a single test. In exchange for Ligotti’s authorization of these urine drug tests, the treatment centers required their patients to regularly visit Ligotti’s clinic, Whole Health LLC, for additional treatment and testing, or allowed Ligotti’s staff to come to their facilities to conduct tests and treatment there. This allowed Ligotti to profit by billing patients’ private health insurance plans for duplicative, medically unnecessary, and expensive urine drug tests, blood tests, and other addiction treatments. As a result of this conduct, which took place from 2011 to 2020, health care benefit programs were billed over $746 million and paid approximately $127 million for fraudulent urine drug tests and addiction treatments. Ligotti pleaded guilty to conspiracy to commit health care and wire fraud in the Southern District of Florida in October 2022 and was ordered today to surrender his medical license. 

LINK: https://www.justice.gov/usao-sdfl/pr/florida-doctor-sentenced-substance-abuse-treatment-fraud-scheme

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UPDATE As of October 5, 2022:

Michael Ligotti pled guilty to Conspiracy to commit health care fraud.  He faces a maximum 20-year prison sentence for taking advantage of scores of vulnerable patients and billing their insurance companies for tests medical experts said were clearly unnecessary.

LINK: https://www.palmbeachpost.com/story/news/courts/2022/10/06/florida-doctor-michael-ligotti-pleads-guilty-health-care-fraud-off-needless-urine-tests/8181497001/

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In the U.S. District Cort, Southern District of Florida, on July 29, 2020:

Florida Doctor Charged in Massive $681 Million Substance Abuse Treatment Fraud Scheme

A Palm Beach County, Florida doctor was arrested and charged with conspiring to commit health care fraud and wire fraud for his alleged participation in a massive years-long health care fraud scheme throughout Palm Beach County, billing for fraudulent tests and treatments for vulnerable patients seeking treatment for drug and/or alcohol addiction.

In a criminal complaint unsealed Thursday, Michael J. Ligotti, D.O, 46, of Delray Beach, Florida, was charged with conspiracy to commit health care fraud and wire fraud. Ligotti made his initial appearance today before U.S. Magistrate Judge Bruce E. Reinhart in the Southern District of Florida.

The complaint alleges that from approximately May 2011 through March 2020, private insurance companies and Medicare were fraudulently billed approximately $681 million for laboratory testing claims and other services as part of this fraudulent scheme, for which they paid approximately $121 million.

"The substance abuse treatment fraud allegedly perpetrated by the defendant sacrificed the genuine care of vulnerable patients at a time when they urgently needed a trusted health care provider," said U.S. Attorney Ariana Fajardo Orshan for the Southern District of Florida. "Health care providers who allow greed to take precedence over their Hippocratic Oath and participate in these schemes are criminals and will be held accountable for their unscrupulous conduct."

According to the complaint, Ligotti owned and operated Whole Health in Delray Beach, Florida. Whole Health was a private clinic, which offered, among other things, addiction treatment, family care, and urgent care.

The allegations in the complaint detail Ligotti's central role in the fraud scheme. Specifically, the complaint alleges that Liggoti: (1) agreed to become the purported "Medical Director" for an addiction treatment facility or sober home for a nominal fee; (2) authorized "standing orders" for hundreds of millions of dollars in medically unnecessary urinalysis tests (UAs), which were billed by testing laboratories that sometimes paid kickbacks to the sober homes or addiction treatment facilities; and (3) in exchange for his signature on these standing orders, required the facilities to have their patients treated by Whole Health and his staff, allowing him to bill hundreds of millions of dollars in additional fraudulent treatments, including unnecessary and expensive UAs, costly blood tests, non-existent therapy sessions, office visits, and other unnecessary services, regardless of whether such treatment and testing were medically necessary and/or actually provided. Ligotti allegedly did not meaningfully review the results of the tests he ordered or use the results of the tests to treat these patients, either at his clinic or at the addiction treatment facilities.

Over the course of the scheme, Ligotti allegedly served as "Medical Director" for more than 50 addiction treatment facilities, and signed over 136 standing orders authorizing such fraudulent tests. According to the complaint, patients at these addiction treatment centers and sober homes were brought to Whole Health and required to submit to testing and treatments authorized by Ligotti, including UA tests at the facilities and at Whole Health. The complaint alleges that the facilities and testing laboratories were also able to bill these patients' insurers for bogus UA tests authorized by Ligotti. In this way, all parties benefited: (1) the laboratories could bill for these medically unnecessary tests; (2) the addiction treatment facilities and sober homes could bill for such unnecessary testing as well, and sometimes received a kickback from the laboratories for each sample they could provide for testing; and (3) Ligotti could bill millions of dollars' worth of medically unnecessary, excessive and duplicative treatments for the patients who were delivered to his office as the condition for him signing the standing orders that fueled the entire scheme in the first place.

The complaint further alleges that Ligotti authorized and conducted UAs and blood tests for revenue-generation and did not use these tests in patient treatment. Ligotti allegedly billed for psychiatric services and therapy sessions that never happened, and that he and his staff were not qualified to conduct. Some patients allegedly were billed between $10,000 and $20,000 by Ligotti and Whole Health for a single day's visit. As charged, Ligotti also utilized multiple nurse practitioners/medical extenders under his practice to fraudulently bill patients' private insurance. Finally, the complaint also alleges that Ligotti improperly prescribed controlled substances, including large quantities of buprenorphine/Suboxone, frequently exceeding the number of patients he was legally authorized to treat. He provided these drugs to patients who did not need it and ignored evidence of possible diversion.

A criminal complaint is merely an allegation and all defendants are presumed innocent until proven guilty beyond a reasonable doubt in a court of law.

For more information:
U.S. Attorney's Office
500 S.Australian Ave. Ste. 400
W. Palm Beach, Fl. 33401

West Palm Beach Main Phone: (561) 820-8711
West Palm Beach Fax Line: (561) 820-8777

Email:Citizen Complaints:[email protected]

Link:https://www.justice.gov/opa/pr/florida-doctor-charged-massive-681-million-substance-abuse-treatment-fraud-scheme