Florida Cardiology Lawsuit: $2M Settlement, Compliance Terms

Florida Cardiology, P.A. and ten of its cardiologists agreed in February 2023 to pay $2 million to resolve a federal whistleblower lawsuit alleging they submitted false claims to Medicare, Medicaid, TRICARE, and the Federal Employee Health Benefits Program. The Florida Cardiology lawsuit accused the Orlando-area practice of billing for cardiac stents that were never inserted, radiofrequency ablations that were never performed, and services delivered while physicians were physically outside the United States.¹ The settlement included no determination of liability.

What the Practice Was Accused of Billing For

The government’s allegations fell into three categories. Drs. Sandeep Bajaj and Karan Reddy allegedly caused the practice to bill for more intravascular stents than were actually inserted into patients. Dr. Bajaj alone was accused of causing the practice to bill for radiofrequency ablations he did not perform, some of which the government said were not performed by any qualifying provider. And all ten physician defendants were accused of causing the practice to bill federal healthcare programs for procedures and services while they were located outside the United States, which those programs generally prohibit.¹

The Justice Department did not disclose the total dollar value of the false claims, the number of phantom stent billings, or how many patients were affected.²

The Cardiologists Named

Ten cardiologists were named alongside the practice: Sandeep Bajaj, Karan Reddy, Abbas Ali, Claudio Manubens, Milan Kothari, Saroj Tampira, Sayed Hussain, Raviprasad Subraya, Harish Patil, and Edwin Martinez.¹ None were excluded from federal healthcare programs as part of the resolution. Dr. Bajaj’s Florida Department of Health practitioner profile reports no final disciplinary action by a licensing agency or specialty board within the past ten years, and no sanction or termination from the Medicaid program.³

How the Case Reached Settlement

The lawsuit began as a qui tam action, the mechanism under the False Claims Act that lets private citizens sue on the government’s behalf. Two relators, Derrick Graham and Jesse Frauenhofer, filed the complaint under seal on September 4, 2018, in the U.S. District Court for the Middle District of Florida.⁴

It stayed sealed for roughly three and a half years while the government investigated. On March 21, 2022, the United States and the State of Florida both filed notices electing to intervene, and the complaint was unsealed eight days later. The government filed a notice of settlement in August 2022, and a final stipulated order of dismissal was entered on February 13, 2023, the same day the Justice Department announced the deal publicly.⁴ Graham and Frauenhofer received $420,000 of the $2 million as their whistleblower share.¹

The Compliance Terms That Came With the Money

Beyond the payment, Florida Cardiology and eight of the ten named physicians entered a three-year Integrity Agreement with the U.S. Department of Health and Human Services Office of Inspector General, effective January 6, 2023. The agreement covers the practice along with Drs. Bajaj, Manubens, Martinez, Patil, Reddy, Kothari, Subraya, and Hussain. Drs. Ali and Tampira were not listed as parties.⁵

Under the agreement, the practice and covered physicians must maintain a compliance program, submit to independent review of their billing and coding, and report certain events to the OIG.⁶ The three-year term runs through approximately January 2026.⁵

1
U.S. Department of Justice. Florida Cardiology PA and 10 Physicians Agree To Pay $2 Million To Settle False Claims Act
2
Cardiovascular Business. Florida Cardiology Practice, 10 Cardiologists Pay $2M To Settle Fraud Allegations
3
Florida Department of Health. Practitioner Profile – Sandeep Bajaj
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CourtListener. Graham v. Florida Cariology PA – Docket
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HHS Office of Inspector General. Florida Cardiology PA Sandeep Bajaj MD – Corporate Integrity Agreements
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AAPC. Florida Cardiology PA Integrity Agreement