The United States of America ex rel Jesse M. Polansky, M.D., M.P.H. v. Geisinger Holy Spirit

CourtDistrict Court, M.D. Pennsylvania
DecidedApril 30, 2025
Docket1:20-cv-00599
StatusUnknown

This text of The United States of America ex rel Jesse M. Polansky, M.D., M.P.H. v. Geisinger Holy Spirit (The United States of America ex rel Jesse M. Polansky, M.D., M.P.H. v. Geisinger Holy Spirit) is published on Counsel Stack Legal Research, covering District Court, M.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
The United States of America ex rel Jesse M. Polansky, M.D., M.P.H. v. Geisinger Holy Spirit, (M.D. Pa. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF PENNSYLVANIA

THE UNITED STATES OF AMERICA ex rel. JESSE M. POLANSKY, M.D., M.P.H.,

Plaintiff, CIVIL ACTION NO. 1:20-cv-00599

v. (SAPORITO, J.)

GEISINGER HOLY SPIRIT, et al.,

Defendant.

MEMORANDUM This is a False Claims Act (“FCA”) action brought on behalf of the United States by a relator, Jesse M. Polansky, M.D., M.P.H. The relator, Dr. Polansky, is a licensed physician with broad-based Medicare, Medicaid, and commercial health insurance experience in evidence-based medicine, utilization review, and informatics. The amended complaint alleges that, after spending eight years as a senior medical officer at a federal agency, the Centers for Medicare & Medicaid Services (“CMS”), Dr. Polansky was employed in this same field by a series of private-sector employers: Executive Health Resources, Inc. (“EHR”) for a two-month period between December 2011 and February 2012; Health Management Systems, Inc., for a period of months between the fall of 2012 and the summer of 2013; Holy Spirit Health System for a

six-month period between December 2013 and May 2014; Delmarva Foundation for an unspecified period during 2014; and Summit Health, for a period of months between the spring of 2015 and August 2015.

Dr. Polansky alleges that the defendants—Geisinger Holy Spirit,1 Geisinger Community Medical Center,2 Geisinger Medical Center,3 and Spirit Physician Services, Inc.4—participated a years-long scheme to

submit fraudulent claims for payment to the United States government. The gist of the amended complaint is that the defendants relied on the fraudulent policies and practices of a billing vendor—Dr. Polansky’s

former employer, EHR—to exploit differences in reimbursement rates for

1 So named in the amended complaint. Geisinger Holy Spirit, formerly known as Holy Spirit Hospital, is a not-for-profit hospital located in Cumberland County, Pennsylvania. It became a Geisinger affiliate in 2014. It was later acquired by Penn State Health in 2020, and it is now known as Penn State Health Holy Spirit Medical Center. 2 Geisinger Community Medical Center is a not-for-profit hospital located in Lackawanna County, Pennsylvania, operated by Geisinger Health System. 3 Geisinger Medical Center is a not-for-profit hospital located in Montour County, Pennsylvania, operated by Geisinger Health System. 4 Spirit Physician Services, Inc., is a not-for-profit organization that manages primary care and specialty physician practices in affiliation with Geisinger Holy Spirit. The amended complaint alleges that it is owned by Geisinger Health System. inpatient and outpatient services, causing them to systematically bill

Medicare and Medicaid for medical services provided to thousands of patients at higher inpatient rates, instead of lower outpatient rates. “The FCA’s provisions authorize private persons to bring

civil enforcement actions on behalf of the United States and to collect a portion of damages that may be awarded if an FCA violation is proven.” , 327 F. Supp. 3d 358, 361

(D. Mass. 2018). The [FCA] requires a [relator], before proceeding with suit, to disclose to the government the information on which the claim is based. The government then has sixty days to investigate the matter and to decide whether to intervene. The government also has the option to step into the action at a later date. In either case, the relator is not entitled to a recovery under the [FCA] if the action is one which runs afoul of the jurisdictional bars contained in 31 U.S.C. § 3730(e). , 123 F.3d 734, 738 (3d Cir. 1997) (citations omitted). The defendants here have moved to dismiss this action under one of these jurisdictional bars, the government action bar,5 which provides

5 The defendants assert several other grounds for dismissal as well, which we do not reach. that: “In no event may a person bring [a False Claims Act action]

which is based upon allegations or transactions which are the subject of a civil suit or an administrative civil money penalty proceeding in which the Government is already a party.” 31 U.S.C. § 3730(e)(3). Although the

FCA’s financial incentive encourages whistle-blowing relators with genuinely valuable insider information to expose fraud, it also attracts parasitic suits based on information already known to the government.

, 559 U.S. 280, 294 (2010); , 9 F.4th 269, 271–72 (5th Cir. 2021); , 327 F. Supp.

3d at 361. The government action bar is intended to discourage such opportunistic behavior. , 9 F.4th at 271–72; , 327 F. Supp. 3d at 361–62. Thus, this statutory provision “must be analyzed

in the context of the twin goals of rejecting suits which the government is capable of pursuing itself, while promoting those which the government is not equipped to bring on its own.”

, 292 F. Supp. 3d 570, 576 (D.R.I. 2017) (internal brackets omitted) (quoting , 24 F.3d 320, 326 (1st Cir. 1994), and , 14 F.3d 645, 651

(D.C. Cir. 1994)). The defendants contend that the instant action is barred because it is duplicative of a prior action initiated by this same

relator concerning the very same allegedly fraudulent scheme, ( ), 422 F. Supp. 3d 916 (E.D. Pa. 2019), , 17 F.4th 376 (3d Cir. 2021), ,

599 U.S. 419 (2023). To prevail on their motion to dismiss, the defendants must show that: (1) the instant action is “based upon” the same “allegations or transactions” involved in the prior litigation; and (2) the

government “is already a party” to that prior litigation. , 327 F. Supp. 3d at 362. In , the relator alleged that EHR exploited a difference

in reimbursement rates for inpatient and outpatient services,6 causing its approximately 2,400 client hospitals to fraudulently bill Medicare and Medicaid by falsely designating patient admissions as inpatient when

6 , 422 F. Supp. 3d at 919 n.3 (noting the relator’s allegation that “Medicare generally pays about $4,000–$5,000 more for inpatient services . . . than it does when the same services are provided to a patient classified as outpatient observation”). they should have been marked as outpatient instead.7 The relator filed

his original complaint in under seal on July 26, 2012, and the government declined to intervene on June 27, 2014. The then-operative second amended complaint was served on EHR and other defendants.

Those defendants filed a motion to dismiss, which was denied on July 26, 2016.8 The parties conducted extensive discovery. This apparently

included several discovery motions, one of which resulted in the imposition of sanctions against the relator for his belated production of a

7 , 422 F. Supp. 3d at 919 n.4 (“[T]here are two potential levels of review for a physician’s initial determination of whether a patient should be classified as inpatient or outpatient.

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The United States of America ex rel Jesse M. Polansky, M.D., M.P.H. v. Geisinger Holy Spirit, Counsel Stack Legal Research, https://law.counselstack.com/opinion/the-united-states-of-america-ex-rel-jesse-m-polansky-md-mph-v-pamd-2025.