NARICIA MCGOWEN FUTRELL, LCSW

Naricia Futrell is an individual behavioral health provider enrolled in Tennessee Medicaid under NPI 1033425483. Almost all of the Medicaid money paid to this provider, 91 percent, is for one code, 90837, which is a one hour psychotherapy session, totaling $1,275,680 over 49 months. In eleven months during 2018, the number of service lines billed under this one provider adds up to more hours of face to face care than a calendar day contains, with the highest month implying 33.0 hours in a day. In several of those months the claims came in through two or three different billing organizations at the same time. The amounts paid per patient per month are close to or below what other providers bill for the same codes, so the question raised by the records is about the hours and the number of lines, not the price of each service.

1. 01The subject is listed in national provider records as NPI 1033425483, Naricia Futrell, an individual provider in Millington, Tennessee, with taxonomy 104100000X and Tennessee as the Medicaid home state. records 1
2. 02Code 90837, psychotherapy for one hour, accounts for $1,275,680 paid over 49 months and 91 percent of this provider's Medicaid dollars, at $203 per patient month, ranking at the 55th percentile of all providers billing this code against a typical $191. records 2
3. 03The provider risk record places the file at evidence tier 2 for impossible volume with concurrency, cites detector D2, lists dollars at risk of $893,393 as the figure of the detector that set the tier rather than a sum, and states that the provider billed more hands on hours than a day holds in 11 months, peaking at 33.0 hours per day across 3 billing organizations, with 91 percent of Medicaid dollars on codes with a history of abuse. records 8
4. 04On August 1, 2018 the claims were flagged as impossible by line count with implied hours per clinician calendar day for personal services of 33.0, a lower bound of 71.1 and a point estimate of 49.5, on $97,850 for codes 90791, 90834, 90837 and 90847 across 3 billing organizations, using the median per line rate source. records 19
5. 05On October 1, 2018 the claims were flagged as impossible by line count with implied hours per clinician calendar day for personal services of 30.2 on $89,388 for codes 90791, 90834, 90837, 90846 and 90847 across 2 billing organizations. records 16
6. 06On September 1, 2018 the claims were flagged as impossible by line count with implied hours per clinician calendar day for personal services of 29.3 on $84,024 for codes 90791, 90834, 90837, 90846 and 90847 across 3 billing organizations. records 13
7. 07On November 1, 2018 the claims were flagged as impossible by line count with implied hours per clinician calendar day for personal services of 25.1 on $72,136 for codes 90791, 90837 and 90847 across 3 billing organizations. records 12
8. 08Additional impossible by line count flags were recorded for January 2018 at 18.9 implied hours and $55,984, February 2018 at 21.9 implied hours and $58,525, March 2018 at 24.3 implied hours and $72,158, April 2018 at 27.0 implied hours and $77,485, May 2018 at 27.7 implied hours and $81,756, June 2018 at 27.5 implied hours and $78,786, and July 2018 at 28.3 implied hours and $83,610. records 14, 11, 10, 15, 9, 17, 18
9. 09Code 90847, family psychotherapy with the patient for 50 minutes, accounts for $62,188 paid over 13 months and 4 percent of Medicaid dollars, at $111 per patient month, ranking at the 39th percentile against a typical $130. records 3
10. 10Code 90791, psychiatric diagnostic evaluation, accounts for $45,039 paid over 27 months and 3 percent of Medicaid dollars, at $70 per patient month, ranking at the 25th percentile against a typical $105. records 4
11. 11Code 90846, family psychotherapy without the patient for 50 minutes, accounts for $8,511 over 6 months at the 30th percentile, code 90834, psychotherapy for 45 minutes, accounts for $7,845 over 17 months at the 15th percentile, and code 90853, group psychotherapy, accounts for $1,417 over 2 months. records 5, 6, 7

Request from the provider and from each of the three billing organizations the daily appointment schedules, sign in sheets, session start and stop times, and signed treatment notes for the eleven flagged months in calendar year 2018, together with payroll and time records for the rendering clinician and any employed or contracted clinicians whose services were billed under NPI 1033425483. Reconcile the paid line counts for codes 90837, 90847, 90791, 90846, 90834 and 90853 against those records to determine how many distinct clinicians actually furnished the services and whether the rendering provider field reflects the person who performed them. Confirm the enrollment, screening and revalidation status of the provider and of each billing organization under 42 CFR 455.410, which requires screening under subpart E as a condition of enrollment and revalidation at least every 5 years. If the records review supports a credible allegation of fraud, the state agency should apply 42 CFR 455.23(a) on payment suspension, including the good cause and partial suspension options, and make the referral to the Medicaid Fraud Control Unit required by 42 CFR 455.23(d); potential exposure for claims for services not provided as claimed may be evaluated under 42 CFR 1003.200.

• The implied hours are estimated from a median per line rate source rather than from documented session start and stop times, so actual session lengths could differ from the modeled durations.
• Claims billed through two or three billing organizations under one individual NPI may reflect supervisory or group practice billing conventions in which services furnished by employed or supervised clinicians are submitted under the supervising provider's number.
• The provider may work across multiple agencies or sites, and duplicate or overlapping submissions from separate billing entities can inflate line counts before adjustments, voids and recoupments are applied.
• Amounts per patient month are at or below peer norms for most codes, at the 55th percentile for 90837, the 39th percentile for 90847, the 25th percentile for 90791, the 30th percentile for 90846 and the 15th percentile for 90834, which is consistent with ordinary pricing.
• Paid claims data can lag, and pending appeals, adjustments or reinstatements may change the paid amounts and line counts shown for the flagged months.
• All flags fall within calendar year 2018, so current billing patterns may differ and should be verified before any payment action.