Billing for Another Company's Staff Under Your NPI Cost Negril $1.8M in Virginia

On October 19, the U.S. Attorney's Office for the Western District of Virginia announced that Negril Incorporated agreed to pay $1,817,910.60 to resolve False Claims Act and Virginia Fraud Against Taxpayers Act allegations. The claims were for mental health skill-building services. The government's theory had nothing to do with whether the sessions happened. It was about whose number was on the claim.

The turn: the clients got the service, and it was still a false claim

According to the release, Negril billed Virginia Medicaid under its own NPI from January 2021 through May 2022. The company that actually delivered the services “did not have its own NPI, was not credentialed through the Virginia Department of Behavioral Health and Developmental Services and was not enrolled as a Medicaid provider.” Under the arrangement, Negril submitted the claims, passed 75 percent of the reimbursement to the other company and kept 25 percent. No allegation in the release says the services weren't delivered.

That 25 percent is why this isn't just a paperwork problem. The money followed the billing identity, not the clinical work.

What the record shows

• The case: United States et al. v. Negril Incorporated et al., No. 6:26-cv-00066 (W.D. Va.), filed June 12, 2026. The Virginia Attorney General's Medicaid Fraud Control Unit and HHS-OIG worked it with the U.S. Attorney's Office.
• The money: HHS-OIG's page says Negril pays over five years.
• OIG's listing: OIG lists Negril under its “Heightened Scrutiny” category, with a five-year duration and the label “Refused on September 21, 2026.” That category is where OIG lists a party that settled without agreeing to a Corporate Integrity Agreement. OIG's description says Negril “proposed an arrangement” under which another person formed a separate company that billed Virginia Medicaid with Negril's NPI.
• The qualifier: these are allegations. There was no admission of wrongdoing and no determination of liability.

The limits

This was a mental health skill-building case, not an ABA case. Nothing in the release mentions behavior analysts, and we haven't seen Virginia's ABA enrollment rules applied to a comparable arrangement. The pattern is portable, though: any practice that lets one entity bill for another entity's staff is exposed to the same question.

What you must know or do

• Owners: list every arrangement where another person or entity delivers services that go out under your NPI, or where you deliver under someone else's. Include subcontracted BCBA groups, staffing partners, management companies and any “umbrella” billing deal. For each one, pull the delivering entity's own Medicaid enrollment record and confirm it is active in every state it serves.
• Owners: read the compensation clause of each. A fixed share of reimbursement, like 75/25 here, paid to or kept by the billing entity is the feature the government pointed to. If you can't state what the retained share pays for, take the contract to counsel before your next claim cycle.
• Billing leads: pick ten recent claims and check that the rendering and billing provider on each is an enrolled entity at the date of service. If one isn't, don't resubmit it. Escalate it first.
• Anyone who finds a gap: the DOJ and HHS-OIG self-disclosure pilot we've covered runs through April 22, 2027. Ask counsel about it before any repayment.