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  1. They are violating Medicare Locum Tenens Laws.
    I practiced for 15.5 years and never bought or sold a practice. Nor did I ever have an associate or partner. Hollern assured me that he had done all of these things multiple times and that he knew exactly how to handle everything. He said the he could bill under my license and credentials with Medicare, Medicaid and all other carriers as he was already doing this at his other locations and he would never do anything illegal.


  2. Failure to report a financial interest in a practice(s).

Most of Hollern’s training offices have the patient sign a blank ABN form or don’t have the form signed at all. Field CAs frequently came to the corporate headquarters for training and did not know what the form was for.

The cash policy is self explanatory.

Pages from the Hollern manual follow that show that Medicare patients are told x-rays are “required”. My former office staff, Mrs., Finnell and Mrs. Swartley can attest to the fact that this was taught during their Uncle Paul training when my office changed hands. Marilyn Sexton did the training and told them to tell this to all Medicare patients.

The earlier discussion of bait and switch tactics deals with free and discounted services to Medicare patients.

Hollern claimed a locum tenens agreement existed beginning October 1, 2003 and was to continue until Stapleton was fully credentialed with all carriers. He also claimed that he intended to continue billing under my license and credentials even if after I moved to my corporate position if Stapleton was not fully credentialed. He also stated that when I quit, he should have been allowed to continue filing under my license and credentials even though I was no longer an employee, seeing patients or had any control over how Stapleton was practicing.

I did not agree to either of the above arrangements. I did not intend to allow them to keep billing under my license or credentials when I left the practice and went to corporate full time. I stopped them from doing so the day I quit.

The attached information from the Medicare manual for chiropractors and other sources disturbs me as it now appears that all billing October 1, 2003 and beyond was inappropriate if not illegal. The information shows that Hollern and Stapleton have violated Medicare and Medicaid laws. It also shows violations of the provider agreements with managed care organizations.

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Editor's Note: Those doctors who would like more information about this complaint may contact Dr. Miller through ChiroWeb at DrMiller@DCMedia.com.

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