Case library / Money, billing and honesty
23 sessions billed in a single day
In short
License revoked
Revoked17.25 hours of psychotherapy. More than 24 sessions a day on 75 different dates. Seven felony counts.
Billing fraud at a scale that is arithmetically impossible to explain, and a separate count for not reporting the conviction.
What happened
A Department of Justice Medi-Cal Fraud and Elder Abuse investigation found that she had billed a managed care organization for as many as 23 individual 45-minute psychotherapy sessions in a single day — 17.25 hours of therapy — on at least two occasions.
She billed one patient for 51 sessions. That patient had been seen once.
Her Medi-Cal billings showed more than ten hours of therapy on 22 different days, including two days of 20.5 hours. Across all plans, she billed more than 24 sessions per day on 75 different dates.
She was charged with seven felony counts of presenting false Medi-Cal claims and seven felony counts of insurance fraud, with aggravating-factor allegations for planning and sophistication, great monetary value, and taking advantage of a position of trust. She pleaded nolo contendere to one felony count and received two years of probation and restitution.
She then ignored the Board's request for an explanation and attempted to withdraw her renewal application.
What it was charged as
Conviction of a crime substantially related to the qualifications, functions or duties of a licensee.
A dishonest, corrupt or fraudulent act — the false claims.
Failure to participate in the Board's investigation, and failure to report the conviction within 30 days.
The outcome
License revoked.
No cost recovery stated in the orderWhat the rule actually says
Note the separate count for failing to report the conviction. 16 CCR §1845 requires a licensee to report any felony or misdemeanor conviction to the Board within 30 days — independently of the Department of Justice, which will report it anyway. Not reporting adds a cause for discipline with a penalty range of its own and removes any argument about candour.
Discussion
Analysis, not part of the decision
The numbers are the case. Twenty-three individual 45-minute sessions in a single day is 17.25 hours of psychotherapy. More than ten hours of Medi-Cal billing on 22 different days, including two days of 20.5 hours. More than 24 sessions a day on 75 different dates. One patient billed for 51 sessions, having been seen once. No account of a clinical practice reconciles with those figures, which is what makes billing data such effective evidence.
This case also entered the Board's world the way most conviction cases do: through the criminal system, not through a client. A Department of Justice Medi-Cal Fraud and Elder Abuse investigation produced seven felony counts of presenting false claims and seven of insurance fraud, with aggravating allegations for planning and sophistication, monetary value, and taking advantage of a position of trust. She pleaded nolo contendere to one count.
Then the separate count. Title 16 §1845 requires a licensee to report any felony or misdemeanor conviction to the Board within 30 days — independently of the Department of Justice, which reports it anyway. Not reporting adds a cause with its own penalty range and removes any argument about candour. She also ignored the Board's request for an explanation and tried to withdraw her renewal application, neither of which stopped anything.
Where insurance reaches, and where it does not
Billing fraud is uninsurable everywhere. What is worth knowing is that a billing audit is not: several therapist policies carry a small sublimit for the cost of responding to a payer's records request or audit, which is the stage before this. That is the coverage to check if you take Medi-Cal or Medicare.
What would have changed it
- Reconcile what your billing service submits against your own calendar quarterly. In a group practice or under a billing company, the claim goes out under your NPI whoever pressed the button.
- Report a conviction to the Board yourself, within 30 days, before the Department of Justice feed does it for you.
Questions
For a law and ethics seminar, or for yourself
- The Board would have learned of the conviction regardless. Why does the reporting duty exist, and why is breaching it charged separately?
- A nolo contendere plea is not an admission of guilt in the criminal matter. What effect does it have in the administrative one?
- What would an employer's or payer's routine audit have caught, and when?
Source. This write-up is drawn from the signed public decision in the case number above. Names, cities and employers have been removed — why. To pull the original, open the Board's quarterly newsletter archive, find the issue covering September 25, 2025, and match the case number in the Formal Disciplinary Actions section. Not legal advice.
