On November 2, 2026, the U.S. Attorney’s Office for the Middle District of Tennessee announced that Premier Medical Group, P.C., a multi-physician practice based in Clarksville, Tennessee, agreed to pay $2.8 million to resolve allegations that it violated the False Claims Act by improperly billing Medicare and TRICARE for services furnished by non-physician practitioners.
The government alleged that, from between 2018 and 2023, Premier submitted claims for services performed by non-physician practitioners using physicians’ National Provider Identifiers (NPIs).
Medicare’s incident-to rules allow qualifying services furnished by auxiliary personnel to be billed under a physician’s or other practitioner’s NPI only when the services comply with state law; the practitioner personally performs the initial service and remains actively involved; the service is integral to normal treatment, commonly furnished in the office or clinic, included in the practitioner’s bill, and an expense to the practice; and the billing practitioner provides direct supervision. In 2026, direct supervision may be provided through real-time audio-video technology for most such services.
NPI Controls Require Claim-Level Validation
The resolution underscores the risk when the rendering professional and claim identifier do not align. A physician’s NPI should not be a default for services performed by another practitioner; the record must support the payer-specific requirements for that identifier and reimbursement level.
Healthcare providers should connect scheduling, credentialing, supervision, documentation, coding, and claim-submission data so billing edits identify mismatches before transmission. Audits should test claims against the medical record and practitioner roster, with targeted review when a service performed by a non-physician practitioner is billed under a physician’s NPI.
GWB represents healthcare providers and other organizations in connection with government investigations, billing compliance, and False Claims Act litigation. If you need assistance with such a matter, contact us today.
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