The Claim: 45 CFR 162.410 is just about NPI standards, not privacy.
"NPI doesn't prove the lease."No, but the Anne Arundel Zoning Permit does—and it's in the nonprofit's name only.
Address entry isn't fraud."It becomes False Claims Act material if it's used to obtain insurance reimbursements for a location they don't legally occupy.
PO Boxes are allowed." Only for individuals (Type 1) who work from home. For organizations (Type 2), it must be a physical site.
Co-location doesn't automatically mean a kickback.
True, but it creates the opportunity and incentive. * The Reality: In Maryland, Fee-Splitting and Corporate Practice of Medicine laws are strict. If the nonprofit (T.I.M.E.) is referring patients to the for-profit (Wellness RX) while they share the same office, phone, and leadership (Ellis/Herron), it triggers an immediate investigation into whether those referrals are "improper remuneration."
"Regardless of federal NPI standards, Maryland COMAR 10.21.20 requires an Outpatient Mental Health Center (OMHC) to be a 'distinct and secure' facility. Can the T.I.M.E. Organization explain how they maintain a 'distinct' clinical facility while their officers use the same phone and suite to operate a for-profit corporation (Wellness RX)?"
Anne Arundel Land Use Navigator (LUN).
Nonprofit T.I.M.E. Organization 410-227-9426 Lauren Herron, COO
For-profit Wellness RX 410-227-9426 Lauren Herron, VPIf Wellness RX (for-profit)
Permit Suite 512 (Exec Office) 410-227-9426 Lamont Ellis,
Individual Lauren Herron (LCSW-C) 410-227-9426 Lauren Herron
Lamont Ellis
Time Organization
Mobile Phone
(410)227-9426
Mailing Address
7310 Ritchie Hwy Suite 512,
Glen Burnie, 21061
United States
Project Description:
PROFESSIONAL OFFICE FOR COUNSELING
72233 - Time Organization - Yes; Professional Office For Counseling;
2018
Record ZCU-2018-75131:
Certificate of Use - Commercial
Record Status: Closed - Approved
CEO lists Suite 100 as its physical practice location but has no lease, no signage, and no independent staff there, it has submitted inaccurate data to a federal registry.
"NPI doesn't prove the lease."No, but the Anne Arundel Zoning Permit does—and it's in the nonprofit's name only.
Address entry isn't fraud."It becomes False Claims Act material if it's used to obtain insurance reimbursements for a location they don't legally occupy.
PO Boxes are allowed." Only for individuals (Type 1) who work from home. For organizations (Type 2), it must be a physical site.
Co-location doesn't automatically mean a kickback.
True, but it creates the opportunity and incentive. * The Reality: In Maryland, Fee-Splitting and Corporate Practice of Medicine laws are strict. If the nonprofit (T.I.M.E.) is referring patients to the for-profit (Wellness RX) while they share the same office, phone, and leadership (Ellis/Herron), it triggers an immediate investigation into whether those referrals are "improper remuneration."
"Regardless of federal NPI standards, Maryland COMAR 10.21.20 requires an Outpatient Mental Health Center (OMHC) to be a 'distinct and secure' facility. Can the T.I.M.E. Organization explain how they maintain a 'distinct' clinical facility while their officers use the same phone and suite to operate a for-profit corporation (Wellness RX)?"
Anne Arundel Land Use Navigator (LUN).
Nonprofit T.I.M.E. Organization 410-227-9426 Lauren Herron, COO
For-profit Wellness RX 410-227-9426 Lauren Herron, VPIf Wellness RX (for-profit)
Permit Suite 512 (Exec Office) 410-227-9426 Lamont Ellis,
Individual Lauren Herron (LCSW-C) 410-227-9426 Lauren Herron
Lamont Ellis
Time Organization
Mobile Phone
(410)227-9426
Mailing Address
7310 Ritchie Hwy Suite 512,
Glen Burnie, 21061
United States
Project Description:
PROFESSIONAL OFFICE FOR COUNSELING
72233 - Time Organization - Yes; Professional Office For Counseling;
2018
Record ZCU-2018-75131:
Certificate of Use - Commercial
Record Status: Closed - Approved
CEO lists Suite 100 as its physical practice location but has no lease, no signage, and no independent staff there, it has submitted inaccurate data to a federal registry.
4
