Did Levine Leichtman unload a sinking ship in InterDent?

I can only hope so. Not that I’m all tore up and concerned about Levine Leichtman. I just find it lip smackin’ good to see another private equity firm that may well get burned over the illegal practice of “Corporate  Dentistry”. Levine Leichtman operated dental clinics under the following names:
Gentle Dental
Smile Keepers
Capital Dental
Blue Oak Dental Group
Mountain View Dental
Affordable Dental Care
Dedicated Dental Systems Incorporated
Also associated with InterDent is Northwest Management Services.
Levine Leichtman Capital Press Release:

LOS ANGELES, Aug. 8, 2012 -- /PRNewswire/ -- Levine Leichtman Capital Partners (LLCP) announced today the closing of the sale of InterDent, Inc. to H.I.G. Middle Market, LLC. 
InterDent, Inc. is a leading dental practice support organization ("DSO") in the United States. The Company  provides support services to over 145 affiliated dental offices in eight western states including California, Oregon, and Washington. InterDent's affiliated offices benefit from professional management, economies of scale, superior information systems, and specialization of functions. Its network delivers comprehensive dentistry to over one million patients annually, including general, orthodontics, periodontics, endodontics, pedodontics, prosthodontics, and oral surgery.
"The InterDent investment has been very successful for our partners, our management team and all of the Company's stakeholders.  We are proud of the successes the company has achieved over the past years and believe the growth will continue with HIG's support," said Lauren Leichtman, CEO of LLCP.  "We are also pleased to provide a very attractive return to LLCP's investors through an exit that underscores our commitment to investing in the middle market."

Seriously?!  According to the WSJ, Levine Leichtman Capital Partners invested in 2000.  They filed for bankruptcy in 2003. Prior to the bankruptcy they owned and operated 226 dental offices in 14 states and now operate 145 dental offices in 8 states.
In 2008. InterDent entered into a 5 year Corporate Integrity Agreement with the Office of Inspector General due to fraudulent billing by at least two of it’s Dedicated Dental clinics in California.  They also agreed to pay $364,500 in restitution and pay $364,500 in damages. The 5 year Corporate Integrity Agreement expires on June 20, 2013.
John Steinbrun signed the Corporate Integrity Agreement as President and CEO of InterDent, Inc and InterDent Service Corporation and Scott Breman signed as President and CEO of Dedicated Dental Systems Incorporated.
I’m sorry, but bankruptcy, a corporate integrity agreement with the OIG, downsizing by 1/3, and numerous lawsuits is considered “very successful” for partners, management or stakeholders.

CSHM–Small Smiles Dental Centers are among exclusive group of 19 under a “Quality of Care” Corporate Integrity Agreement with US government

There are 346 Corporate Integrity Agreements individuals and corporations have signed with the Office of Inspector General (OIG).  Out of those 346 only 19 have the distinguished designation as being “Quality of Care Corporate Integrity Agreements”.  Church Street Health Management (f/k/a FORBA)  is among the exclusive bunch.

According to the OIG Quality of Care CIA’s:

I think Small Smiles Dental Centers and Church Street Health Management is on the verge of more sanctions

Before I get into this, let me say the following is not even close to being based on anything other than my observations. Maybe that sounds a bit odd to admit.  But according to the covey of “artful dodgers” at Small Smiles Dental Centers and Church Street Management, everything on this blog has no basis and is pure hogwash.  So I don’t know why they visit here forty ‘leven times a day.


However, I’m smelling something happening at 618 Church Street, Nashville, Tennessee.  I’ve heard “chatter”  CSHM is reviewing their “breach” of the Corporate Integrity Agreement (CIA) signed in January 2010 with the Office of Inspector General.
1.   I’m told they are scurrying to gauge exactly how far from the truth the reports sent to the OIG, as required by the CIA, with their actual patient/parent complaints from the third party call center, employee exit interviews, employee complaints via the “hotline” and Daily Patient Logs, that reveal the actual overtreatment still taking place on a daily, patient by patient basis.

Small Smiles Dental Centers: Reporting of Adverse Events

The Corporate Integrity Agreement requires Church Street Health Management to self report what is referred to as “Reportable Events” that take place at their Small Smiles Dental Centers across the US. 
What is a “Reportable Event” as seen by Small Smiles Dental Clinics:

1. Billing that would generate more than $4000 in overbilling – Keep erroneous or any fraudulent bilking billing under that mark and they are good to go.  Is that per child?  Could also be defined as a matter that a reasonable person would consider a probable violation of civil, criminal or administrative law applicable to federal health care programs . Or a matter that a reasonable person would consider likely to render CSHM insolvent.
2. Quality of Care Reportable Event– Adverse Events (AE).  These are a bit more difficult to define, since they are in the eyes of the beholder.  Basically anything that involves a violation of the obligation to provide items or services of a quality that meets professionally recognized standards of care.  In my opinion, that would include unlocking the door to any of the now, 72 clinics. The great White Paper King, Steven Adair is making those decisions.  Not a good choice in my opinion.  What is his pay based on?   Does he get a “production” bonus too? It may be that these are only events reported that cause a Corrective Action Plan (CAP) to be initiated.  What is a CAP, you ask?  Well, it could be a simple letter of instruction to the treating dentist/staff member,  a DVD for them to watch, or further training that they decide will do.
3. Event that would cause law enforcement to be notified–  I wonder if that means local law enforcement or the Feds?  You know what I mean, a dentist punches a patient in the face or staff forges names and signatures on documents?  Could also be defined as a matter that a reasonable person would consider a probable violation of civil, criminal or administrative law applicable to federal health care programs .  Again I feel that unlocking the doors on these houses of horrors should be criminal since I promise something illegal happens in each one of them everyday.

If CSHM doesn’t correct the billing within 30 days or

FORBA Small Smiles Employees CIA Compliance Is Up To You; Includes Warning To Future Employees

ATTN:  All FORBA Small Smiles Employees

ATTN: Potential Employees: This is a must read before you agree to be employed by FORBA or any of its Small Smile clinics.  Full disclosure is a must!

FORBA has entered into a Corporate Integrity Agreement (CIA) with the Office Of Inspector General (OIG) after being caught red handed committing fraud and mistreating children.  (not only red handed but on video!)

Of course FORBA admitted no wrong doing as they will be quick to tell you.  However, anyone who would rather pay $24 million dollars plus interest and sign a 67 page set of rules to follow for the next 5 years, is probably guilty in my opinion.

[I would say FORBA was probably thinking this was a deal compared to what might happen if they didn’t agree and further delving into FORBA’s setup would likely reveal much worse things happening, that’s a scary thought isn’t it?]

When push comes to shove, it’s you, the employee on the front lines to see that the provisions in the CIA are followed.  I would highly recommend you download and take time to read the rules since you are the main one playing the game.  It’s your butt out there.  You may not have signed it, but you are as legally bound by this agreement as if...