7 audits to run on scribe and template notes before a whistleblower does

The patients never left their cars. At dozens of drive-through and walk-up COVID-19 testing sites in Texas, staff checked them in and collected a nasal swab, and that was the visit. The claims told a different story, according to the government: level 3 and level 4 evaluation and management services, backed by notes with sections for past medical history and a physical exam.

On Oct. 7, Heal 360 Urgent Care, Heal 360 Primary Care and owner Mohammed Amer Mohiuddin, MD, agreed to pay $20 million to resolve those False Claims Act allegations, according to the Department of Justice. The government alleges the template notes were produced by remote scribes overseas and that Mohiuddin was listed as the rendering physician on most claims without treating patients at the sites. The settlement resolves two whistleblower suits, and the relators will receive $3.4 million. The claims are allegations only, and there has been no determination of liability.

The program billed was a pandemic-era fund for uninsured patients, but the mechanics are not unique to it. Any practice that relies on note templates, outsourced scribes or ambient AI documentation carries the same basic exposure: a chart that says more than the encounter did. Here are seven audits to run before someone inside your practice runs them for the government.