|Dr. Michael W. Davis|
Contrasting Dental Medicaid Enforcement: Florida versus Texas
By: Michael W. Davis, DDS
Dr. Michael W. Davis maintains a general dental practice in Santa Fe, NM. He serves as chairperson for Santa Fe District Dental Society Peer-Review. Dr. Davis also provides a fair amount of dental expert legal work for attorneys. He may be contacted via email: MWDavisDDS@comcast.net
Both Florida and Texas share similarities in that both states have long standing Republican state legislatures, state attorney generals, and state governors. Likewise, both states enjoy highly diverse ethnic and economic population demographics. However, each state handles enforcement of dental Medicaid very differently.
Dental Medicaid fee schedule rates in Texas are some of the highest nationally, while Florida’s are at or near the bottom.1,2,3 Texas has attracted a huge bevy of corporate dental chain Medicaid providers, headquartered both in-state and out-of-state. Florida has a paucity of such interstate dental Medicaid corporate providers.
Although dental Medicaid fee schedule payouts are substantially higher in Texas, both states’ fee schedules fall below the UCR (usual and customary rates) of the average insurance company. With dental Medicaid remunerations below the overhead costs of most private dental practices, only a minority of licensed dentists sign on as Medicaid providers. Those doctors who obtain Medicaid credentialing generally do so to serve a limited number of patients on a charity basis, or work in the public sector. There are some disturbing exceptions.
There are a minority of “outlier” dentists whose goal is to scam the Medicaid program, and make little effort to cover their tracks.4-7 Added to this number are many more devious Medicaid fraudsters, in which only skilled dentist auditors can identify.
Florida dental regulatory authorities have been quicker to turn over cases of suspected Medicaid fraud and abuses to their state’s attorney general’s office. This has occurred far less frequently in Texas, despite Texas being a far more populous state with far greater numbers of dental Medicaid providers.
Extent and Examination of Dental Medicaid Fraud and Abuses
We’ve already learned from the recent limited examination (four states) by federal Health and Human Services- Office of Inspector General (HHS-OIG), that approximately 9-11% of dental Medicaid providers are grossly over-the-top in abusive Medicaid billings.4-7 These specific providers are termed “outliers”. Depending on the state reviewed, one-third to 50% is employed by large group practices (primarily corporate dental chains called “dental support organizations”, “DSOs”). One must remember, these are the worst of the Medicaid program violators, and not the majority with scams designed to “fly under the radar”. Outliers only represent the easy to identify, low hanging fruit.
Typically the cleverer Medicaid fraudsters (non-outlier cheats) upcode Medicaid services or provide gross over-treatment, which isn’t discovered as easily by a HHS-OIG audit.8 One common fraud technique is upcoding of dental sealants on permanent teeth, to multiple surface posterior resin restorations.9 Others place multiple steel crowns on deciduous (baby) teeth, which have minimal to no evidence of dental decay, or are soon to naturally exfoliate (naturally come out).10,11 Another favorite dental Medicaid scam has been the service of a pulpotomy on deciduous teeth (baby tooth root canal), into teeth with little caries (tooth decay) near the tooth’s nerve.12-14 In fact, the author has specifically heard this referenced as a “preventative pulpotomy”, in interviews with former corporate dental employees. Of course, the bitter cynicism and avarice towards the patient’s welfare by this terminology of “preventative pulpotomy” shouldn’t be lost on the dental profession, auditors, or the general public.
Perhaps unique to Texas, we saw an entrenched old-boy element of the dental profession work to alter and amend standard accepted dental terminology, to expand Medicaid eligibility. Texas Medicaid orthodontics (corrective movement of teeth) eligibility required “ectopically erupted teeth”. Insiders simply changed the Medicaid definition of “ectopically erupted tooth” from the dental industry standard definition, to include any tooth which may be malpositioned, angled, tipped, slightly rotated, etc.15 These schemers circumvented the intent of the law, and lined their pockets either through providing direct Medicaid services or for-profit courses to dentists, on how to beat the system.16
An additional component of Texas dental Medicaid fraud-by-design was Medicaid payments not for completion of an orthodontic case, but for payments on a per-visit basis. Obviously, financial incentive was established to continually yo-yo patients in active treatment, in and out of a dental office. No consideration was afforded to transportation challenges for disadvantaged children. Further, there was a serious disincentive to complete orthodontic treatment in a timely manner, in the patient’s best interest. In the years 2009-2011 Medicaid orthodontic payments in Texas outstripped the payments for all other 49 states combined.17
Texas declined to provide dental Medicaid oversight and monitoring on the state level, and delegated this responsibility (for a significant fee to the taxpayer) to the highly discredited Xerox Corporation.18,19 The federal HHS-OIG agreed with Texas, that Xerox failed in their contractual obligations of dental Medicaid oversight. However, the federal Inspector General stated the State of Texas is ultimately responsible for the disturbingly remiss oversight.20
In fact, services of Xerox were so egregiously lax, that’s it’s difficult to see this as anything other than political pay-to-play. All the while, dental Medicaid fraudsters, both large and small were free to ply their trade in fraud-craft. Texas state authorities provided the illusionary mantle of oversight via a wasteful model of collusion, with big business/big government crony capitalism.
The most common Medicaid unlawful scheme of non-profit dental clinics (federally qualified health centers or FQHCs) is via abuse of “patient encounters”.21 To date, we’ve only see this frequent Medicaid scam addressed by government regulators to much extent in Washington and New York.22,23 This particular abuse of taxpayer money is a favorite with certain public health clinics, Native American title 638 clinics, and non-profit healthcare facilities. Generally we don’t see rank-and-file healthcare providers managing this particular fraud mechanism. Usually fraud is generated though the unlawful systems of directors and managers (some are physicians and dentists), who enjoy very inflated salaries and benefits, by cheating programs designed to serve the disadvantaged.
To its credit in Texas, the non-profit United Medical Centers Board of Directors (Maverick, Kinney, and Val Verde Counties) recently terminated employment of their Chief Executive Officer and Medical Director after an internal investigative audit.24
One would like to assume nonprofit organizations are distanced from scamming taxpayers. However, that assumption has proven inaccurate and very dangerous. Schemes defrauding the dental Medicaid program are highly pervasive, lucrative, and relatively easy to pull off. Dental Medicaid fraud and abuses are ubiquitous both in the private and public sectors. The largess which comes to those who defraud American taxpayers from dental Medicaid scams has in fact become an entrenched and fully accepted dental industry model of business.
Handling and Mishandling of Dental Medicaid Cases
Both Texas and Florida have historically operated under a failed enforcement model of “pay and chase”.25,26 Medicaid payments are made to providers (or their corporate beneficial owners, usually DSOs) year after year without question or examination. If an audit is eventually generated, it then becomes a massive records undertaking. Government regulators usually lack funds to retain meaningful dentist auditors, to thoroughly review patient records and billings. Behind the 8-ball, government prosecutors nearly always settle cases for pennies on the dollar, and no admission of wrong-doing by violators.
By contrast, the dental insurance industry mandates pre-authorizations prior to a provider billing for a vast number of patient services. Questionable services and payments are better “nipped in the bud”. Payments are better held in check, not as easily getting out of hand.
Payment holds from the private insurance industry generally are upfront from the onset, on an individual case-by-case basis. By contrast, Medicaid payment holds are usually well down the road, and may represent many hundreds of thousands of dollars or even several million dollars. Medicaid payment holds are formulated by deviations in billings, which are assumed to represent patterns of fraud and abuse. Obviously, a long-term pattern of abusive billings must be established, prior to control of taxpayer (public) monies. Private insurance companies, which have their own set of difficulties, rarely allow fiscal problems to build to this crisis level.
prosecution of Dr. Tuan “Terry” Truong is a case worth examination.27
Dr. Truong was employed by Kool Smiles Dental in Abilene, Texas, for over a
year. After conviction for Medicaid fraud, Dr. Truong was fined and sentenced
to federal prison for 18-months. The statement released by Kool Smiles Dental
acknowledged their full cooperation with the government’s investigation and
prosecution. Yet, Kool Smiles Dental monitors daily production metrics for each
of their dentist providers. It seems inconceivable, corporate management didn’t
fully realize the inappropriate and unlawful activities of Dr. Truong at a very
early stage. Yet, government prosecutors were very willing to accept a low
level dentist Medicaid cheat for a guaranteed felony conviction, versus those
pulling the strings at higher levels. One is left to wonder what real rats
could be convicted, if Dr. Truong were offered a deal to finger corporate
management at the DSO level, or even private equity level.
|Dr. Tuan "Terry" Truong|
Former Texas Attorney General (today Governor) Greg Abbott gave much ballyhoo to his settlement deal with alleged dental Medicaid fraudster, Dr. Richard Malouf for $1.2 million dollars.28 This settlement only represented pennies on the dollar for the true extent of the alleged fraud (many $10s of millions of dollars). Naturally, there was no admission of wrong-doing by Dr. Malouf, former owner of All Smiles Dental.
Adding insult to injury of taxpayers, Greg Abbott (R) remanded prosecution of a similar criminal case against
Dr. Richard Malouf to then Dallas district attorney Craig Watkins (D).29,30 Mr. Abbott was able to “kill two birds with one stone”. Since Watkins had accepted political “donation” money from Dr. Malouf’s wife, he wasn’t inclined to go forward with Malouf's prosecution. Dr. Malouf would be protected from a criminal action. Once the political scandal was revealed against Watkins, a rising star in the Texas State Democratic Party would be expunged. Watkins lost the ensuing election for Dallas district attorney. Sadly, this makes Governor Greg Abbott a political and financial puppet master, in Texas. “In the land of the blind, the one-eyed man is king.”
|Dr. Richard Malouf|
|Dr. Thomas Floyd|
Dr. Thomas Floyd, a pediatric dentist specialist in West Palm Beach, accumulated years of Medicaid patient complaints. Dental Board disciplinary actions were always squelched. No cases were remanded to the state attorney general’s office. Seemingly, Dr. Floyd flew for free.
Eventually, the local and national media got hold of the story.32,33 FloridaAttorney General Pam Bondi had gotten somewhat ahead of the story, and initiated investigation and indictments prior to most media reports.34 Multiple felony charges were filed against Dr. Floyd. In the final outcome, Dr. Floyd walked with a wrist-slap of no admission of wrong-doing and surrendering his dental license, at age 62.
|Dr. Howard Scheider|
Of particular note is the case of alleged Medicaid fraud against Dr. Merys Downer-Garnette of Winter Park, FL.38,39 The dollar amount of alleged fraud only totals $5,500. The dentist was arrested and indicted on felony fraud charges. This sum of money represents peanuts in the world of dental Medicaid fraud. One is left to wonder why a settlement wasn’t earlier reached.
The state’s dental expert reviewing the case is Dr. William Robinson of Tampa. Dr. Robinson is a former member of the Florida Board of Dentistry and an educator offering professional colleagues courses in patient recordkeeping, treatment planning, and patient informed consent. Florida wisely secured the services of a quality expert in its prosecution of the defendant.
Back in 2010, Dr. Downer-Garnette surrendered the sum of $87,000 in Medicaid billing claims. No sanctions ensued against her dental license, and it was seemingly back to business as usual (cheating taxpayers), with only the standard wrist-slap. Obviously, wrist-slap regulation didn’t seem to be effective as a deterrent. Further, it’s difficult to imagine $5,500 is all dental expert, Dr. William Robinson, was able to designate for bogus Medicaid billings. The case is still pending, and all defendants are innocent until or unless proven guilty.
Problematic Nonprofit Sector
Interestingly, DentaQuest, a nonprofit Medicaid administrator, operates both in Florida and Texas. DentaQuest recently purchased the nonprofit dental provider; Sarrell Dental.40 The conflict of interest of a non-profit Medicaid administrator merging with a Medicaid provider is self-evident.
DentaQuest’s president for Care Delivery serving Alabama, Kentucky, and Texas is Todd Cruse. Mr. Cruse formerly served as a chief executive to the disgraced and today bankrupt, Small Smiles Dental. Small Smiles Dental was cited by the US Justice Department for numerous instances of Medicaid fraud and abuses, as well as failures to meet mandatory corporate integrity agreement overseen by the federal HHS-OIG.41,42 Todd Cruse’s former employer was eventually disqualified from business with government health programs because of habitual violations. Seemingly even in the nonprofit dental Medicaid services sector, the fox guards the hen house.
One can easily argue, low dental Medicaid fee schedule rates act as a disincentive, for interstate corporate dental entities (most of which are problematic) to do business in Florida. Why expand into Florida, for lesser money, and a higher likelihood one’s employee dentists will eventually be audited and possibly disciplined? Florida, unlike Texas, has not fully accepted dental Medicaid fraud as an approved and viable business model. Some cynics might contend Florida remains in denial.
Of course Florida must accept the downside. Low dental Medicaid remunerations mean very few ethical and honest private sector dentists seek Medicaid credentialing, except to serve on a limited charity basis. Medicaid eligible patients often struggle to find dental providers, ethical or otherwise. Fraud is kept in better check, but at the cost of fewer available providers.
By contrast, Texas has built dental Medicaid fraud into monster proportions. It’s probably the most lucrative dental business model in the state. Arguably, dental Medicaid fraud today represents a Texas “jobs program”. Providers, large corporate or otherwise, fully realize there will be few if any consequences for cheating the Medicaid program. The state HHSC-OIG has given fraudsters a pass. The fact that Texas Medicaid fee schedules are probably the nation’s best paying is also an added incentive to cheat the system. Yes, some things truly are bigger in Texas. Dental Medicaid fraud is just one such item.
At worst in Texas, dental Medicaid crooks usually walk away, for a settlement of pennies on the dollar and no admitting wrong-doing. DSOs, which beneficially own many dental clinics defrauding taxpayers in Texas, can easily throw an employee doctor under the bus, which allows a larger criminal organization to carry on with business as usual. Employee dentists are fully expendable, as the situation calls for. Any limited dental Medicaid fraud investigation and potential indictments in Texas, only represent a mild “speed bump” in the course of dishonest business.
The worst of the worst dental Medicaid providers (“outliers” as termed by federal HHS-OIG) may only represent 9-11% of Medicaid dentists. However, the taxpayer dollars defrauded by “outliers” may represent 20-30% or more of total dental Medicaid expenditures. This completely ignores the majority of dental Medicaid cheats and violators functioning without auditing or examination at any level currently. For example, in Texas we witnessed over 90% of Medicaid orthodontic expenditures were billed outside Medicaid rules.
In Texas specifically, dental Medicaid, a program initially designed to assist the disadvantaged, has morphed into a “welfare for the rich” scam. Texas has expanded dental Medicaid largely based on a business model of fraud, into a vast state jobs program. Neither Texas nor Florida is close to placing interests of disadvantaged patients to the fore. Both states operate highly dysfunctional dental Medicaid programs, but in very different ways.
Texas certainly serves far more patients, and those patients arguably have far greater access to highly questionable and problematic providers. Disadvantaged Medicaid-eligible Texas patients are often placed in an untenable situation. Like the old classic Mississippi Delta blues song, Born Under a Bad Sign says in the refrain, “If it wasn’t for bad luck, I’d have no luck at all”.
Neither state offers adequate remuneration to attract enough ethical and honest dental Medicaid providers. Texas authorities seem to have better accepted and promoted, that regulatory crackdown on Medicaid violators in this wasteful government program will deplete the number of providers. Remove the cheats and there won’t be many providers remaining, as has been confirmed in Florida.
Dental Medicaid is such a toxic program in both Texas and Florida (and most states), that the entire system requires a complete redesign. Both states demonstrate different models for failed government managed healthcare and enforcement.
It doesn’t seem to matter if administration, oversight, fee scheduling, and enforcement is provided directly by the state or delegated to an outside entity, via a corrupt “pay-to-play” scheme. Patients fail to derive adequate clinical standard of care either way. Taxpayer money is wasted either way. We the US taxpayers, and disadvantaged citizens, deserve far better from government.
The interests of patients and taxpayers must have first priority. The interests of so-called “stakeholders”, who are often milking the system dry, should carry little to no significance. Governmental authorities who support crony capitalism by protecting the well-established industry of dental Medicaid fraud must be spotlighted and stopped.
A government healthcare program which offers patient services below the true costs to provide those services incentivizes fraud, waste, and abuses. The majority of honest and skilled providers largely opts out of Medicaid participation, or only participates to a very limited basis (charity). Broad based participation is disincentivized. The remaining participating stakeholders (both individual dentists and DSOs) are too often the dregs of the dental profession. The interests of disadvantaged patients too frequently assume a backseat to corporate profits, lifestyles of nonprofit clinic directors, and dishonest dentists. Patient care suffers under the fantasy of top-down government direction, which supports the industry of dental Medicaid fraud.
Whatever dollar amount state legislatures and governors decide to spend on dental Medicaid must have a program designed to attract the very best clinicians available. Our nation’s poor and disadvantaged don’t merit dental care from the minority of crooks and deviants within the dental profession. If the scope of patient care must be limited to reflect the real overhead costs involved, so be it. The stark reality of quality, but limited healthcare, is vastly superior to the myth of comprehensive dental care, but in fraudulent and iatrogenic measures.
2. Florida Medicaid General Dentistry Fee Schedule. July 1, 2013. Accessed PDF Jan 4, 2016. https://www.flrules.org/gateway/ruleno.asp?id=59G-4.002&Section=0
3. Texas Drills Down on Medicaid Dental Fraud, The Wall Street Journal, August 19, 2012, July 17 2014. http://online.wsj.com/news/articlesSB10000872396390444233104577591243154716520
4. Department of Health and Human Services Office of Inspector General. Questionable Billing for Medicaid Pediatric Dental Services in Louisiana. Aug 2014. http://oig.hhs.gov/oei/reports/oei-02-14-00120.pdf
5. Department of Health and Human Services Office of Inspector General. Questionable Billing for Medicaid Pediatric Dental Services in Indiana. Nov 2014. http://oig.hhs.gov/oei/reports/oei-02-14-00250.pdf
6. Department of Health and Human Services Office of Inspector General. Questionable Billing for Medicaid Pediatric Dental Services in California. May 2015. http://oig.hhs.gov/oei/reports/oei-02-14-00480.pdf
7. Department of Health and Human Services Office of Inspector General. Questionable Billing for Medicaid Pediatric Dental Services in New York. Mar 2014. http://oig.hhs.gov/oei/reports/oei-02-12-00330.pdf
8. US Senate Finance and Judiciary Committees. US Senate Joint Staff Report on the Corporate Practice of Dentistry in the Medicaid Program. June 2013. http://www.adea.org/uploadedFiles/ADEA/Content_Conversion_Final/policy_advocacy/Documents/emailDist/Report_on_Corporate_Dentistry.pdf
9. Davis MW. Mechanisms of Dental Sealant Scams. Dentist the Menace online dental news blog. Sept 16, 2014. http://blog.dentistthemenace.com/2014/09/mechanisms-of-dental-sealant-scams.html
10. Heath D, Rosenbaum J. Complaints about Kids’ Care Follow Kool Smiles. Frontline in partnership with The Center for Public Integrity. June 26, 2012. http://www.pbs.org/wgbh/frontline/article/complaints-about-kids-care-follow-kool-smiles/
11. Hagan D. Corporate Dentistry Bleeds Medicaid, Vulnerable Low-Income Children. Coalition against Insurance Fraud. Jan 8, 2015. http://www.insurancefraud.org/article.htm?RecID=3398#.VotTAfkrK70
12. American Academy of Pediatric Dentistry. Guideline on Pulp Therapy for Primary and Immature Permanent Teeth. Revised 2014. http://www.aapd.org/media/policies_guidelines/g_pulp.pdf
13. Barrett S. Massive Dental Fraud Uncovered. Dental Watch. Aug 23, 2011. http://www.dentalwatch.org/news/forba.html
14. Alliance for Natural Health- USA. Dentists Take Advantage of Children on Medicaid. Health Impact News. June 30, 2015. http://www.anh-usa.org/dentists-take-advantage-of-children-on-medicaid/
15. Domino D. Judge Finds Credible Evidence of Medicaid Fraud by Texas Clinic. DrBicuspid.com. Mar 5, 2014. http://www.drbicuspid.com/index.aspx?sec=sup&sub=pmt&pag=dis&ItemID=315276
16. Davis MW. Analysis of ADC vs. Texas Health and Human Services Commission. DrBicuspid.com. Mar 6, 2014. http://www.drbicuspid.com/index.aspx?sec=wom&pag=dis&ItemID=315284
17. Harris B, Smith M. Crooked Teeth: Medicaid Millions. WFAA News 8 Dallas. Jan 9, 2012. http://www.wfaa.com/story/news/local/investigates/2014/08/15/13823510/
18. Aaronson B. Texas Cancels Medicaid Contract, Sues Xerox over Alleged Misspent Money. The Texas Tribune. May 9, 2014. http://www.texastribune.org/2014/05/09/texas-sues-xerox-recover-millions-misspent-money/
19. State of Texas v. Xerox Corporation et al. Filed Travis County, TX. Pdf file. https://www.texasattorneygeneral.gov/files/epress/files/XeroxLawsuit.pdf
20. Department of Health and Human Services Office of Inspector General. Texas Did Not Ensure That the Prior-Authorization Process was Used to Determine the Medical Necessity of Orthodontic Services. Aug 2014. http://oig.hhs.gov/oas/reports/region6/61200039.pdf
21. Davis MW. Scams on the Public by Nonprofit Dental Clinics. Dentist the Menace online dental news blog. Jan 26, 2015. http://blog.dentistthemenace.com/2015/01/scams-on-pubic-by-nonprofit-dental.html
22. New York Office of Attorney General. A.G. Schneiderman Announces $325,000 Settlement with Erie County Dental Clinic. Jan 9, 2012. http://www.ag.ny.gov/press-release/ag-schneiderman-announces-325000-medicaid-fraud-settlement-erie-county-dental-clinic
23. Washington State Office of the Attorney General. Sea Mar Health Centers to Pay $3.35 Million in Attorney General’s Office Investigation of Improper Billing. Jan 16, 2015. http://www.atg.wa.gov/news/news-releases/sea-mar-health-centers-pay-335-million-attorney-general-s-office-investigation
24. Landa JG. United Medical Centers Board of Directors Terminate CEO George Kypuros and Medicaid Director Dr. Juan Saucedo. Eagle Pass Business Journal. Oct 1, 2015. http://www.epbusinessjournal.com/2015/10/united-medical-centers-board-of-directors-terminate-ceo-george-kypuros-and-medical-director-dr-juan-saucedo/
25. Department of Health and Human Services Office of Inspector General. Medicaid Third Party Liability Savings, but Challenges Remain. Jan 2013. http://oig.hhs.gov/oei/reports/oei-05-11-00130.pdf
26. Brino A. ‘Pay and Chase’ Fades as Insurers Seek Revenue Integrity. Healthcare Payer News (division of Healthcare Finance News and Healthcare IT News). Apr 7, 2014. http://www.healthcarepayernews.com/content/pay-and-chase-fades-insurers-seek-revenue-integrity#.Vo4AgPkrK70
27. The United States Attorney’s Office Northern District of Texas. Abilene, Texas, Dentist Pleads Guilty in Medicaid Fraud Scheme. Aug 27, 2013. http://www.justice.gov/usao-ndtx/pr/abilene-texas-dentist-pleads-guilty-medicaid-fraud-scheme
28. The Attorney General of Texas. A Dental Office Clinic Agrees to Pay to Resolve Medicaid Allegations Made by State and Federal Officials. Mar 21, 2012. https://texasattorneygeneral.gov/oagnews/release.php?id=3997
29. Harris B. AG Calls DA’s Settlement with Dallas Dentist a ‘Sweetheart Deal’. WFAA Dallas News 8. Oct 30, 2013. http://www.wfaa.com/story/news/2014/08/18/14048832/
30. Krause K, Timms E. Texas AG’s Office Blasts Watkins over Handling of Medicaid Fraud Case. The Dallas Morning News. Mar 5, 2013. http://www.dallasnews.com/news/community-news/dallas/headlines/20130305-texas-ags-office-blasts-watkins-over-handling-of-medicaid-fraud-case.ece
31. Domino D. Texas Officials Giving Up on Most Medicaid Fraud Cases. Dr.Bicuspid.com. Oct 30, 2015. http://www.drbicuspid.com/index.aspx?sec=sup&sub=pmt&pag=dis&ItemID=318716
32. Burstein J. Dentist Accused of Physically, Verbally Abusing Children He Treated. Sun Sentinel. Sept 22, 2013. http://articles.sun-sentinel.com/2013-09-22/news/fl-thomas-floyd-dentist-20130922_1_dentist-thomas-floyd-former-employees
33. Gonzales D. Dental Practice Closed After Patient Abuse Allegations. NBC 6 South Florida Investigators. Nov 19, 2013. http://www.nbcmiami.com/investigations/Dental-Practice-Closed-After-Patient-Abuse-Allegations-232510121.html
34. Florida Office of the Attorney General. Attorney General Bondi’s Office Arrests West Palm Beach Dentist on Medicaid Fraud and Grand Theft Charges. Feb 8, 3013. http://www.myfloridalegal.com/newsrel.nsf/newsreleases/884414CF74BD2F0E85257B0C005D68E6
35. Florida Office of the Attorney General. Duval County Pediatric Dentist Arrested for Medicaid Fraud. Nov 17, 2015. http://www.myfloridalegal.com/newsrel.nsf/newsreleases/F6E2AE742652A17F85257F0000531450
36. Gutman M, Good D. Florida Investigating Allegations Dentist Preformed Unnecessary Procedures to Collect on Medicaid. ABC News. May 22, 2015. http://abcnews.go.com/US/florida-investigating-allegations-dentist-performed-unnecessary-procedures-collect/story?id=31229153
37. Pelican G. Pediatric Dentist Accused of Torture, Abuse, Fraud. USA Today. May 8, 2015. http://www.usatoday.com/story/news/nation/2015/05/08/pediatric-dentist-abuse-fraud-lawsuit/26969291/
38. Florida Office of the Attorney General. Orange County Dentist Arrested for Defrauding Medicaid Out of More than $5500. Sept 24, 2015. http://www.myfloridalegal.com/newsrel.nsf/newsreleases/492CA2CC3666D45685257ECA004FDDD7
39. Freed T. Winter Park Dentist Arrested for Medicaid Fraud. Winter Park/ Maitland Observer. Oct 8, 2015. http://www.wpmobserver.com/news/2015/oct/08/winter-park-dentist-arrested-medicaid-fraud/
40. Ranaivo Y. Sarrell Dental to become Affiliate of DentaQuest. Birmingham Business Journal. Sept 20, 2013. http://www.bizjournals.com/birmingham/news/2013/09/20/sarrell-dental-to-become-affiliate-of.html
41. The United States Department of Justice. National Dental Management Company Pays $24 Million to Resolve Fraud Allegations. Jan 20, 2010. http://www.justice.gov/opa/pr/national-dental-management-company-pays-24-million-resolve-fraud-allegations
42. Office of Inspector General US Department of Health and Human Services. OIG Excludes Pediatric Dental Chain from Participation in Federal Health Care Programs. Apr 3, 2014. http://oig.hhs.gov/newsroom/news-releases/2014/cshm.asp