Author Topic: Fraudulent Healthcare Providers Targeting Natives  (Read 4187 times)

Offline educatedindian

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Fraudulent Healthcare Providers Targeting Natives
« on: August 12, 2023, 03:29:40 pm »
https://nativenewsonline.net/health/arizona-adds-more-fraudulent-providers-to-investigation-into-massive-medicaid-scheme-targeting-native-americans?utm_source=Native+News+Online&utm_campaign=1a023b8fec-EMAIL_CAMPAIGN_2021_11_24_COPY_01&utm_medium=email&utm_term=0_dfd2540337-1a023b8fec-1412483443
Arizona Adds More Fraudulent Providers to Investigation into Massive Medicaid Scheme Targeting Native Americans
Yahoo News

BY DARREN THOMPSON  AUGUST 10, 2023
PHOENIX — Arizona’s Medicaid program added 31 more providers, some Native American- owned and operated, to its list of fraudulent healthcare providers who participated in a multi-million dollar statewide Medicaid scam that targeted Native Americans.

Native News Online reported in May that Arizona Governor Katie Hobbs announced that more than 100 healthcare providers are under investigation for insurance fraud that targeted American Indians and scammed the state’s Medicaid program hundreds of millions of dollars.

In the months leading up to the state’s announcements, the reports surfaced of Navajo Nation citizens being picked up in white vans or SUVs and being taken off tribal lands to sober living facilities. Some people have been reported as missing and, in some situations, have been found in behavioral health facilities in Arizona. Victims are often left abandoned, with no way to get home.
 
Arizona law enforcement authorities and the Arizona Health Care Cost Containment System (AHCCCS) received reports alleging that many of the named facilities do not provide the services they are paid to provide. Instead, patients are untreated, sometimes given drugs and alcohol, and enrolled in the AHCCC’s American Indian Health Plan (AIHP), which pays the facilities for services.

AHCCCS said in a fact sheet on its website that “credible evidence has been established that individuals were targeted and aggressively recruited with false promises of food, treatment, and housing, only to be taken to facilities where providers billed for services that were not provided or were not appropriate or necessary.”

AHCCCS also provided several examples of how some providers were billing for services, including billing for excessive hours of services in a 24-hour period for a single person, billing a single person for multiple services during the same time period, or billing for services that weren’t provided.

As a result of the state’s May announcement, many providers ended operations leaving many people displaced. The same week of the state’s announcement, the Navajo Nation launched “Operation Rainbow Bridge” to assist its tribal citizens who may need assistance finding services at another location or transportation to or near the Navajo Nation. Leaders have called the scam a widespread humanitarian crisis.

While Arizona authorities are cracking down on fraudulent healthcare providers and “prosecuting bad actors” per the May 16 announcement, the scam has spread beyond the state’s borders as far as Montana.

U.S. Senator Jon Tester, a Democrat from Montana, wrote a letter on July 19, 2023 to Honorable Chiquita Brooks-LaSure, Administrator of Centers for Medicare and Medicaid Services, saying Montana Tribal citizens were recruited and abandoned in the fraud scheme.

“While it is unacceptable the Arizona State Medicaid program allowed this fraud to plague Arizona’s Tribal Communities for so long that it spread to other States, the Centers for Medicare and Medicaid Services (CMS) also failed to identify this fraudulent waste of taxpayer dollars in the agency’s oversight capacity,” Senator Tester wrote to CMS, a federal agency in the U.S. Department of Health and Human Services. “State Medicaid programs and CMS share responsibility for ensuring that Medicaid is used to deliver health care services and not misused for fraud, waste, or abuse, and it’s clear that responsibility was not taken seriously.”

The Blackfeet Tribal Business Council in Montana passed a resolution on August 3, prohibiting the solicitation and recruitment of individuals within the Blackfeet Reservation's exterior boundaries to attend fraudulent behavioral health treatment facilities anywhere in the State of Arizona. The resolution also establishes a civil penalty, including permanent banishment from the Blackfeet Indian Reservation.

Laura McGee, a Blackfeet Nation Intergovernmental liaison, told Native News Online that tribes need to take preventative measures to protect their citizens.

“I would like protocols and vetting to be done by our Tribes,” McGee said. “Detox centers at our Indian Health Service (IHS) hospitals, along with inpatient treatment services for opioids.”

Housing is not a service provided by AHCCCS, but because the reimbursement rate was so high, many providers invested in properties to house clients. They then filled properties with as many people as possible while billing them for staying in them or receiving services 24 hours a day. Some properties let people come and go because legally they can, and alcohol and drug use has been reported at some locations. Some also discharged people from their properties for any reason or no reason at all.

 There is widespread activity of people who also abuse the loopholes in the system, jumping from location to location to see which provider can offer the most benefits. It’s an easy way for people evading the law to go to as well, where background checks are not required for people receiving healthcare services. If clients are threatened by owners, they respond with claims to report providers to the state.

AHCCCS’s Office of Inspector General and the Attorney General’s Office said on its website that it became aware of potential fraudulent billing practices, including significant increases in billing for outpatient behavioral health services.

 “These circumstances triggered a multi-agency review and investigation of potential fraud, waste, and abuse,” AHCCCS said in a fact sheet. “Ultimately, this led AHCCCS to connect the irregular billing of these services with alleged criminal activity targeting Indigenous peoples and other vulnerable Arizonans.”

Since the state’s announcement in May, AHCCCS has made a number of changes that affect both providers and patients in the behavioral health service industry. Reimbursement for services has been lowered for providers who are licensed to provide behavioral and mental health services, and enrollment in the AIHP must be completed in person.

Previously, reimbursement rates for providing intensive outpatient treatment, or IOP as it’s called in recovery communities, were upwards of $1,400 for three hours of service per day. Since May 1, the reimbursement rate for IOP services has been nearly $150 per day.

AHCCCS announced on June 28 that it will no longer accept enrollment into the AIHP over the phone. The change is an additional measure to prevent fraudulent enrollment. Also, all new enrollment requests must be submitted in writing to AHCCCS by fax or email by an Indian Health Service (IHS), Tribally-owned/and or operated 638 facilities, or Urban Indian Health Organization on behalf of a member. Previously, all one needed to do to enroll in the AIHP was submit a photo of one’s tribal enrollment or identification card, or a copy of one’s tribal identification, over the phone.

Last month, U.S. Attorney’s Office announced that a Mesa woman pleaded guilty to Wire Fraud and Money Laundering and is scheduled to be sentenced on Sept. 18, 2023. Through various businesses, she admitted she received more than $22 million in payments from fraudulent billing practices targeting people enrolled in AHCCCS’s AIHP. She billed people for services who were deceased or incarcerated and omitted information required when applying for licensure by the state.

Some of the added suspended providers include Blue Sage Healing Center and Sunrise Native Recovery, both Phoenix-based providers that claim to be Native American owned and operated. Together, they allege to have provided services to hundreds of Native American clients over the last several years. Emails to both were left unanswered.

“Our own Native American people are involved, as well,” said McGee, whose advocacy also facilitated Senator Tester’s letter to CMS and resulted in a resolution passed by the Tribal Council. Some companies include “Native” in their company names, often misleading others who are legitimately seeking help. 

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https://www.azahcccs.gov/Fraud/Downloads/ProviderSuspensionsTerminations.pdf
AHCCCS performs terminations in accordance with A.R.S. § 36-2930.05 and the terms of the Provider
Participation Agreement each provider must sign to register with AHCCCS. AHCCCS may terminate for a
variety of reasons including, but not limited to, lack of licensure, quality of care concerns, and lack of
disclosure of certain information or persons....
The document below provides a list of active suspensions of providers starting with FFY 2020 to the present.
SUSPENDED AS OF 8/11/2023
Trinity Integrated Health 1427644475 Suspend 8/1/2023
Empire Wellness and Treatment Center LLC 1992431027 Suspend 7/28/2023
Anthony Bratko 1093195810 Suspend 7/28/2023
A New Path Recovery LLC 1093433872 Suspend 7/28/2023
Psych Services, LLC 1033516208 Suspend 7/28/2023
Joseph Franzetti 1639246341 Suspend 7/28/2023
Allegro Health 1548990526 Suspend 7/28/2023
Phoenix House Recovery 1962083543 Suspend 7/28/2023
Life In Your Hands LLC 1649908096 Suspend 7/28/2023
C&N Mental Health 1871226670 Suspend 7/28/2023
Blue Sage Healing Center 1083337463 Suspend 7/28/2023
Building Resilience 1841867686 Suspend 7/28/2023
Heros Advocacy Group 1700408622 Suspend 7/28/2023
MD Labs 1699045674 Suspend 7/21/2023
Happy House Behavioral 1376263657 Suspend 7/21/2023
Native Music Coalition 1689295636 Suspend 7/21/2023
Heart of Harbor Integrated IC 1750044988 Suspend 7/21/2023
Sunrise Native Wellness 1831833169 Suspend 7/21/2023
Sunrise Native Recovery 1164197869 Suspend 7/21/2023
Zkala IC 1275257917 Suspend 7/21/2023
Christian3 Mega Clinic 1215634928 Suspend 7/14/2023
Affirmed Wellness Outpatient Treatment Center 1730804972 Suspend 6/23/2023
Aspiring Anew Generation 1760198329 Suspend 6/23/2023
Native Rising of Arizona, LLC 1417679648 Suspend 6/23/2023
The Healing Hands Clinic, LLC 1245939461 Suspend 6/23/2023
Thinking Learning Together 2, LLC 1790432979 Suspend 6/1/2023
Chow Counseling Family Services, LLC 1639775927 Suspend 6/1/2023
Gold Mettle Recovery, LLC 1124779962 Suspend 6/1/2023
Z Hope 1861198590 Suspend 6/1/2023
A New Day Arizona 1558091686 Suspend 5/18/2023
A to Z Life Centers LLC 1447838693 Suspend 5/18/2023
Dream Chasers Family Services 1134841679 Suspend 5/18/2023
Essential Wellness Solutions 1316554421 Suspend 5/18/2023
Keep Going Counseling 1790351658 Suspend 5/18/2023
One Community AZ, LLC 1043922149 Suspend 5/18/2023
Paradise Treatment Services 1639815467 Suspend 5/18/2023
Supportive Community Services, LLC 1770123614 Suspend 5/18/2023
Ulu Care, LLC 1790443216 Suspend 5/18/2023
4A HEALTHCARE LLC 1689293177 Suspend 5/15/2023
A D ADULT AND YOUTH CEN 1760063770 Suspend 5/15/2023
AGAPE HEALING HOUSE LLC 1962165506 Suspend 5/15/2023
Agricola Wellness Center 1447970066 Suspend 5/15/2023
ALL AND ALL BEHAVIORAL HE 1578105144 Suspend 5/15/2023
ALL LIVES MATTER 1972221885 Suspend 5/15/2023
Allied Behavioral Health 1467195198 Suspend 5/15/2023
AMELIORATE HEALTH CARE LL 1801469655 Suspend 5/15/2023
ANGEL HEART SERVICES LLC 1326653312 Suspend 5/15/2023
APACHE HEALTH 1154936953 Suspend 5/15/2023
ARTEMIS OF ARIZONA LLC 1194451989 Suspend 5/15/2023
ASSURANCE PROFESSIONAL MA 1932767944 Suspend 5/15/2023
AUDACIOUS LIVING LLC 1326652652 Suspend 5/15/2023
Axios Wellness Center, LLC 1225707235 Suspend 5/15/2023
BELLA S CARE LLC 1902491046 Suspend 5/15/2023
BEYOND HOPE BEHAVIOR HEAL 1447829015 Suspend 5/15/2023
BIG STAR EMPOWERMENT 1992323141 Suspend 5/15/2023
BoraBora Integrated Health 1568103182 Suspend 5/15/2023
BRIDGE OF HOPE FAMILY SERVICES 1235881103 Suspend 5/15/2023
Bright Beginning Counseling Center LLC 1871209965 Suspend 5/15/2023
BRIGHTER LIFE LLC 1457911737 Suspend 5/15/2023
Caasi Health Services, LLC 1942880893 Suspend 5/15/2023
CACTUS WREN COMMUNITY SER 1457976813 Suspend 5/15/2023
Calm Integrated Healthcare LLC 1225765951 Suspend 5/15/2023
CHRISTOPHERS HOUSE 1912637463 Suspend 5/15/2023
CIRCLE OF HOPE 1003488206 Suspend 5/15/2023
Community Directions 1407422660 Suspend 5/15/2023
COURAGEOUS MINDS LLC 1285376574 Suspend 5/15/2023
CREATIVE FAMILY HEALTH 1235624297 Suspend 5/15/2023
DEBBIES HOUSE LLC 1114699774 Suspend 5/15/2023
Desert Tranquility Integr 1699432963 Suspend 5/15/2023
DINA L HILL MBR (GOOD NEIGHBOR 1013511674 Suspend 5/15/2023
DONISHA PARDUE 1902052954 Suspend 5/15/2023
Eagle Treatment Center 1255079273 Suspend 5/15/2023
Eclipse Psychiatry Outpatient 1114664570 Suspend 5/15/2023
Embark Wellness Center LLC 1912645433 Suspend 5/15/2023
FAMILY HEALTH CARE SERVIC 1497350664 Suspend 5/15/2023
Focused Family Services, LLC 167991136 Suspend 5/15/2023
FOOTSTEPS TOWARDS SOLUTIONS 1134741119 Suspend 5/15/2023
Fountains of Hope 1194479345 Suspend 5/15/2023
FRESH START BEHAVIORAL HE 1275113698 Suspend 5/15/2023
FRESH START RESOURCE CENTER 1326650417 Suspend 5/15/2023
GENESIS COMMUNITY LLC 1598346991 Suspend 5/15/2023
George Simon 1659983542 Suspend 5/15/2023
GOING THE EXTRA MILE LLC 1538731500 Suspend 5/15/2023
GREATER HEIGHTS BEHAVIORA 1881279172 Suspend 5/15/2023
Habour Health Integrated 1386352599 Suspend 5/15/2023
HEARD HEALTH CARE LLC 1053920454 Suspend 5/15/2023
HELPING HEARTS FAMILY SERVICES 1659941771 Suspend 5/15/2023
HELPING THE COMMUNITY LLC 1639758675 Suspend 5/15/2023
HIGHER HEIGHTS HUMAN SERV 1679134506 Suspend 5/15/2023
HIGHER HEIGHTS HUMAN SERV 1013508084 Suspend 5/15/2023
HOPE HAVEN LLC 1972127462 Suspend 5/15/2023
Hope Light Care Recovery, LLC 1568100865 Suspend 5/15/2023
HOUSE OF GRACES LLC 1073106373 Suspend 5/15/2023
HOUSE OF TABITHA LLC 1477138766 Suspend 5/15/2023
HUMBLE HELPING 1528778909 Suspend 5/15/2023
Ican Health Care & Services 1932859600 Suspend 5/15/2023
Integrated Behavioral Care & Wellness Center LLC 1588376297 Suspend 5/15/2023
Joyd Wellness Center 1427762236 Suspend 5/15/2023
Lema Clinic LLC 1922727510 Suspend 5/15/2023
Life Stream Treatment Center 1427723683 Suspend 5/15/2023
Lifetorch Recovery Center 1760101794 Suspend 5/15/2023
Light Center Behavioral Health LLC 1700598489 Suspend 5/15/2023
LOTUS HEALTH (DONISHA PARDUE) 1922638055 Suspend 5/15/2023
LOVE THY NATIVE 1396457024 Suspend 5/15/2023
LOVING CARE IN HOME HEALT 1821749318 Suspend 5/15/2023
MAX CARE CENTER LLC 1437768892 Suspend 5/15/2023
MEDFORDS FAMILY SERVICE 1215697297 Suspend 5/15/2023
Mindflex Outpatient Treatment Center LLC 1649978347 Suspend 5/15/2023
Mireille Wellness Clinic 1821722778 Suspend 5/15/2023
Motherland Counseling, LLC 1720716608 Suspend 5/15/2023
NEW LIFE WELLNESS CENTER 1164013959 Suspend 5/15/2023
NEW LIFE WELLNESS FLAGSTA 1144983180 Suspend 5/15/2023
NEXT LEVEL CRISIS CONNECT 1346843901 Suspend 5/15/2023
NEXT LEVEL VITALITY LLC 1407402316 Suspend 5/15/2023
NUCREATIONS FAMILY SERVICES 1750035705 Suspend 5/15/2023
One Point Psychiatric Service 1194453688 Suspend 5/15/2023
OPEN HAND LLC 1629729116 Suspend 5/15/2023
Pinetop Behavioral Health 1407586852 Suspend 5/15/2023
PRIDE FAMILY SERVICES 1699378091 Suspend 5/15/2023
PROFESSIONAL CARING KINGS 1265012116 Suspend 5/15/2023
Progressive Living Wellness 1235863531 Suspend 5/15/2023
PROPER PATHS LLC 1750047072 Suspend 5/15/2023
PUSHING THROUGH COMMUNITY 1255824470 Suspend 5/15/2023
Putting U First LLC 1932788486 Suspend 5/15/2023
Rebirth Center LLC 1285386359 Suspend 5/15/2023
Rehema Behavioral Health 1619595485 Suspend 5/15/2023
RESILIENT COMMUNITY CARE 1942894761 Suspend 5/15/2023
RIGHT VIEW HEALTH SERVICE 1356900344 Suspend 5/15/2023
SAFETY NEST 1700515798 Suspend 5/15/2023
Salosaa LLC 1720653934 Suspend 5/15/2023
Samia Psychiatry IOP 1265151807 Suspend 5/15/2023
SAVING LIVEZ LLC 1417695347 Suspend 5/15/2023
SELECT BEHAVIORAL HEALTH 1801408737 Suspend 5/15/2023
SMITH-ZEN HOME 1790307486 Suspend 5/15/2023
SUMMER S DAWN CENTER 1659917722 Suspend 5/15/2023
TAYLORD WELLNESS 1093340606 Suspend 5/15/2023
Theophilus/Akoh 1275908444 Suspend 5/15/2023
TRANQUILITY BEHAVIORAL HEALTH 1548971807 Suspend 5/15/2023
Trauma Prevention and Recovery 1396498812 Suspend 5/15/2023
Indigenous Health 1043974702 Suspend 4/20/2023
Life Care Premier Service 1164039723 Suspend 4/20/2023
Wells of Hope 1437883857 Suspend 4/20/2023
1 Family Clinic LLC 1023626090 Suspend 4/7/2023
Divine Changing Hands 1124649777 Suspend 4/7/2023
Lotts 2 Love 1033827753 Suspend 4/7/2023
Bonds of Hope 1841860855 Suspend 4/3/2023
Brighter Tomorrow's Counseling 1790359537 Suspend 4/3/2023
Brighter Tomorrow's Family Services 1710586144 Suspend 4/3/2023
Gibson Lane 1750024519 Suspend 4/3/2023
Hope and Haven Family Services 1215538111 Suspend 4/3/2023
Narrative 1952069098 Suspend 4/3/2023
Peace of Pi 1104548627 Suspend 4/3/2023
A Better Day 1861117772 Suspend 3/24/2023
Imani Mental Health Svcs 1639703879 Suspend 3/24/2023
Imani Wellness LLC 1679168454 Suspend 3/24/2023
Joanne Rop 1487291712 Suspend 3/24/2023
Universal Wellness 360 1528715323 Suspend 3/24/2023
Zac Rop 1922643998 Suspend 3/24/2023
Bows Center 1538899174 Suspend 3/3/2023
Community Hope Wellness 1881309367 Suspend 3/3/2023
Desert Sage Healing 1699379990 Suspend 3/3/2023
New Stages LLC 1275174369 Suspend 3/3/2023
NHouse Inc NONE Suspend 3/3/2023
Rita Anagho 1205150174 Suspend 3/3/2023
Riteway Trans 1427491406 Suspend 3/3/2023
TUSA Integrated Clinic LLC 1346974763 Suspend 3/3/2023
For a Better You Wellness 1023788031 Suspend 2/16/2023
Aspire Community 1194318097 Suspend 2/9/2023
Newfound Hope 1558090019 Suspend 2/9/2023
PBS 1548835549 Suspend 2/9/2023
BCFL Next Steps 1548918279 Suspend 2/6/2023
Elite Innovative Health 1881264273 Suspend 2/6/2023
Heal Within Family Services 1396318309 Suspend 2/6/2023
Marvin Smith 1467196022 Suspend 2/6/2023
Step by Step Recovery 1891410510 Suspend 2/6/2023
United Natives Health 1710609151 Suspend 2/6/2023
Logan Family Health 1306587126 Suspend 1/18/2023
Beyond4Wallz 1760084644 Suspend 12/29/2022
Community Hope Wellness 1922733641 Suspend 12/29/2022
I Hope Medical Trans 1528304102 Suspend 12/21/2022
Keys Community OTC 1669013629 Suspend 12/21/2022
Roaming Med Transport NONE Suspend 12/21/2022
Unmerited Favor Special 1730765066 Suspend 12/21/2022
Supreme Positive 1003401902 Suspend 12/16/2022
A New Day Community Health 1588025902 Suspend 12/1/2022
Agape Love Community Center 1548861701 Suspend 12/1/2022
Hidden Peaks 1881351856 Suspend 12/1/2022
A New Day Arizona 1427649631 Suspend 10/19/2022
Arizona Center for Family Betterment 1285258848 Suspend 10/19/2022
Triple PPP 1912406877 Suspend 10/19/2022
Triple PPP 1598373037 Suspend 10/19/2022
Paradise Valley Home Care NONE Suspend 9/30/2022
A Man Tran 1053663229 Suspend 9/8/2022
Dial-A-Ride 1376697052 Suspend 9/8/2022
A Path of Resilience 1497372908 Suspend 7/27/2022
Helping Hands Realty 1548882467 Suspend 7/27/2022
180 Wellness Center 1730798562 Suspend 3/24/2022
A Better Living Health 1124690011 Suspend 2/28/2022
New Horizons Behavioral 1275194946 Suspend 2/28/2022
Arizona Recovery Treatment 1336785518 Suspend 1/7/2022
Arizona Wellcare, LLC 1366088585 Suspend 11/12/2021
Better Choices 4 Life, LLC 1598308470 Suspend 11/12/2021
Michael Gray Sole MBR 1033671565 Suspend 11/12/2021
Reflections Health Services, LLC 1134680820 Suspend 11/12/2021
Harbor Health Integrated 1902434236 Suspend 10/1/2021
Safe Keeping Counseling 1336790781 Suspend 10/1/2021
Beacon Wellness Center 1386267797 Suspend 9/3/2021
Harmony Family Services 1881249639 Suspend 9/3/2021
Harmony Family Services 1912535337 Suspend 9/3/2021
Kaleidoscope LLC 1629570379 Suspend 9/3/2021
Apogee Behavioral Health Service 1437742954 Suspend 8/24/2021
Apogee Integrated Health 1306439948 Suspend 8/24/2021
Apogee Intregated Health 1154914109 Suspend 8/24/2021
Apogee Mental Health Serv.... 1477110526 Suspend 8/24/2021
Aurtism, LLC 1710521802 Suspend 7/21/2021
Therapy Mental Health and Wellness, LLC 1376165266 Suspend 7/21/2021
1st Class Shuttle Express 1588815781 Suspend 5/5/2021
Denga Medical Trans LLC 1417297037 Suspend 5/5/2021
Engaging Life Center... 1679112619 Suspend 4/15/2021
A Making Changes LLC 1972956670 Suspend 11/4/2020
Agnes Centers For Domestic... 1609376698 Suspend 11/4/2020
A-Making Changes 1780245506 Suspend 11/4/2020
Babbit & Bowers Behavioral 1154954113 Suspend 11/4/2020
Gentle Touch Behavioral Health 1346764081 Suspend 11/4/2020
Good Samaritan Homes 1669938478 Suspend 11/4/2020
Mary Group Home II 1477060341 Suspend 11/4/2020
Mary Group Home LLC 1033645668 Suspend 11/4/2020
Medical Clinic of AZ 1629490149 Suspend 11/4/2020
Nevada First Choice 1023572658 Suspend 11/4/2020
Ohana Behavioral Services 1467014563 Suspend 11/4/2020
Sun Valley Services,Inc 1467636092 Suspend 11/4/2020
Together Time LLC 1013471986 Suspend 11/4/2020
Harmony Healthcare 1891190195 Suspend 7/7/2020
A &N Services, LLC 1396081667 Suspend 6/5/2020
Desert Mobile Transportation 1376844332 Suspend 5/29/2020
Freedom AZ, LLC 1366881872 Suspend 5/29/2020
Philia Homecare LLC 1932693207 Suspend 5/29/2020
Philia Homecare LLC NONE Suspend 5/29/2020
Love Shines LLC 1164070819 Suspend 1/31/2020
Enable Therapy, LLC 1083088694 Suspend 12/3/2019
Head to Toe Therapy 1851797807 Suspend 11/15/2019
Head to Toe Therapy, LLC 1497959670 Suspend 11/15/2019