Anesthesia Billing Fraud Suit Properly Dismissed, Court Affirms

A whistleblower failed to show that a federal district court erred in dismissing her False Claims Act suit alleging that PST Services LLC improperly billed Medicare for anesthesia services, the Ninth Circuit said Tuesday.

Nicole O’Neill failed to allege sufficient facts to show that PST submitted false claims to the government and made false statements material to those claims, the US Court of Appeals for the Ninth Circuit said in a nonprecedential opinion affirming the lower court’s dismissal.

O’Neill alleged that PST, when billing for services provided at a California hospital, used a “QZ modifier” code to describe care from ...