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Billing under my license at any point was inappropriate. Continuing beyond my employment would definitely have been inappropriate.

Hollern's and Stapleton's use of my credentials and license did not fit the Medicare or Medicaid description for locum tenens, “incident to” rules, reciprocal billing or substitute physician.

I regret trusting Hollern and his attorney and not looking this information up prior to signing the sale and employment contracts and allowing them to bill in my name. Technically, Hollern and Stapleton owe the money they received from billing under my license and credentials back to Medicare, Medicaid and all other carriers.

Hollern's billing arrangement was his idea and he billed to suit his needs. He did not follow the locum tenens rules for any of the organizations I was credentialed with. Even if he had followed the rules a locum tenens agreement ends in 60 days for Medicare. It is typically only 14 days for Medicaid. With special arrangements (permission) for Medicaid it can be 90 days. There are apparently NO locum tenens arrangements in the majority of managed care company contracts.

Hollern and Stapleton placed my reputation with all carriers at risk and their actions could have resulted in being thrown out of their plans and not being allowed to participate in them in the future. Hollern and Stapleton should have to repay all funds issued from these carriers from October 1, 2003 through January 8, 2004. The dates they billed under my license.

Hollern assured me that his billing tactics in all of his offices were perfectly normal. He had not practiced for two years but all the services in his Hillview office were billed under his license (2002-2003). The training doctor and the students were actually treating the patients.

Everything in the Preston Office was billed under Jason Goodman's license and everything in the Clarksville office was billed under Joe Roger's license. This is despite the fact that these doctors were not in the office 50% of the time. Again, the students (some licensed, some not) were seeing the patients. Dr. Goodman caught on to the problems and lies in the Hollern system and got out as I did. Dr. Rogers stayed despite being made aware of the problems. I believe that Dr. Goodman is prepared to cooperate with the investigation that will result from this complaint.

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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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