United States of America v. Healthcare Associates of Texas LLC

District Court, N.D. Texas·Decided October 15, 2024·No. 3:19-cv-02486·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF TEXAS DALLAS DIVISION

UNITED STATES OF AMERICA, § ex rel. CHERYL TAYLOR, § § Plaintiff, § § v. § Civil Action No. 3:19-CV-02486-N § HEALTHCARE ASSOCIATES OF § TEXAS, LLC, et al., § § Defendants. §

MEMORANDUM OPINION AND ORDER

This Order addresses Relator Cheryl Taylor’s motion to exclude expert testimony of Alice Gosfield, Daniel Shay, Tony Cobos, and Gregory Russo [457]. Because the Court finds that each of these experts meets the requirements of Rule 702, the Court denies the motion. I. ORIGINS OF THE DISPUTE This case arises from claims under the False Claims Act, 31 U.S.C. § 3729, et seq. (“FCA”), against Defendants Healthcare Associates of Texas, LLC, Healthcare Associates of Irving, LLP, David Harbour, Jeff Vines, Kristian Daniels, Dr. Charles L. Powell, Dr. David Deems, Dr. Walter Gaman, and Dr. Terrence Feehery (collectively, “HCAT”). Taylor alleges that she observed HCAT employ fraudulent Medicare billing practices. The Court has discussed Taylor’s factual allegations at some length, see, e.g., United States ex rel. Taylor v. Healthcare Assocs. of Tex., LLC, 2023 WL 3294141, at *1 (N.D. Tex. 2023), and the Court will not recount them in great depth here. Taylor now moves to exclude four of HCAT’s expert witnesses. II. LEGAL STANDARD FOR EXPERT TESTIMONY

Under Federal Rule of Evidence 702 a witness must be qualified as an expert by “knowledge, skill, experience, training, or education.” FED. R. EVID. 702. A qualified expert may testify if the expert’s specialized knowledge will help the trier of fact and (1) “the testimony is based upon sufficient facts or data,” (2) “the testimony is the product of reliable principles and methods,” and (3) “the expert’s opinion reflects a reliable

application of the principles and methods to the facts of the case.” Id. District courts must determine that expert testimony “is not only relevant, but reliable,” and make “a preliminary assessment of whether the reasoning or methodology underlying the testimony is scientifically valid” and “can be applied to the facts in issue.” Daubert v. Merrell Dow Pharms., Inc., 509 U.S. 579, 589, 592–93 (1993); see also Kumho Tire Co. v. Carmichael,

526 U.S. 137, 150–51 (1999) (holding Daubert principles apply to all types of experts). The focus, however, “must be solely on principles and methodology, not on the conclusions that they generate.” Daubert, 509 U.S. at 595. District courts have broad discretion to determine the admissibility of expert testimony. Sims v. Kia Motors of Am., Inc., 839 F.3d 393, 400 (5th Cir. 2016). But the

rejection of expert testimony is the exception, not the rule. In re DePuy Orthopaedics, Inc. Pinnacle Hip Implant Prods. Liab. Litig., 2016 WL 9560113, at *3 (N.D. Tex. 2016). The Daubert inquiry may not replace the adversarial system. Pipitone v. Biomatrix, Inc., 288 F.3d 239, 249–50 (5th Cir. 2002). “[V]igorous cross-examination, presentation of contrary evidence, and careful instruction on the burden of proof are the traditional and appropriate means of attacking shaky but admissible evidence.” Id. at 250 (quoting Daubert, 509 U.S. at 596). Indeed, “while exercising its role as a gate-keeper, a trial court must take care not

to transform a Daubert hearing into a trial on the merits.” Id. III. THE COURT DENIES THE MOTION TO EXCLUDE TESTIMONY OF GOSFIELD, SHAY, AND COBOS

HCAT retained Alice Gosfield, Daniel Shay, and Tony Cobos — all of whom are healthcare lawyers — to testify about whether HCAT’s practices were consistent with Medicare and Texas rules and industry custom. Gosfield opines on Medicare billing practices. Rel.’s Appx. 448 [456]. Shay opines on Medicare credentialling and enrollment. Id. at 643–44. And Cobos discusses HCAT’s delegation to medical assistants. Id. at 6. Taylor moves to exclude their testimony, arguing that they render impermissible legal conclusions and that Gosfield and Shay are unqualified. Rel.’s Mot. Exclude 1–13 [457]. Taylor does not contest Cobos’s qualifications, or any of Gosfield, Shay, and Cobos’s reliability or evidence sufficiency. Because the Court finds that these experts meet the requirements of Rule 702, the Court denies the motion to exclude their testimony.

A. Gosfield and Shay are Qualified

The Court finds that Gosfield and Shay are qualified as experts to render the opinions in their reports. Gosfield gives opinions on five practices at HCAT: incident-to billing, enrollment and billing privileges, standing orders, Annual Wellness Visit billing, and physical medicine billing. Rel.’s Appx. 447. She states that HCAT’s practices in these areas were “reasonable and consistent with industry standards.” Id. at 448. Gosfield’s experience with healthcare law renders her qualified to make these opinions. Gosfield has a J.D. from NYU and has fifty years of experience practicing healthcare law and advising medical practices on regulatory topics. Id. at 445. She has

authored fifteen published articles dealing with Medicare issues, including incident-to billing and physician supervision. Id. She has co-authored a book on Medicare Fraud. Id. She has also advised the Department of Health and Human Services on practical implementation of it laws and regulations. Id. at 446; Defs.’ Resp. Gosfield 5 & n.3 [498]. This education and experience renders her qualified to give the opinions outlined in her

expert report. Taylor takes issue with some aspects of Gosfield’s report, arguing that her lack of knowledge of medical coding; the Provider Enrollment, Chain, and Ownership System (“PECOS”); and Texas law makes her unqualified. Rel.’s Mot. Exclude 6–7. The Court disagrees.

First, Gosfield’s opinions are not about medical coding. She discusses industry custom as it relates to various billing practices at HCAT. She is not opining on the propriety of any specific claim. Instead, she evaluates HCAT’s general practices. Second, it is immaterial that she has no experience with PECOS. PECOS is the system where providers can manage their Medicare enrollment. Defs.’ Resp. Gosfield 5–6. But lack of

experience with PECOS is irrelevant because Gosfield’s opinions go to the legal requirements and industry practices, not to the functional aspects of the enrollment platform. Third, Gosfield’s lack of Texas law expertise does not affect her testimony. Gosfield did testify that compliance with state law is a “predicate for any of the services that Medicare pays for.” Rel.’s Appx. 809. But, to the extent that expertise in state law is required, Gosfield appears to defer to Cobos instead of offering her own opinions. See, e.g., id. at 482. Accordingly, the Court finds that Gosfield is qualified as an expert to give

the opinions in her report. The Court also concludes that Shay is qualified as an expert to give his opinions on HCAT’s Medicare enrollment and credentialling practices. He has a J.D. from Emory University and has practiced for twenty years. Rel.’s Appx. 640. He specializes in advising healthcare practices on Medicare enrollment and reassignment issues. Id. He has

published writings on these topics, including as chapters in the Health Law Handbook. Id. Accordingly, he is qualified to opine on Medicare enrollment and credentialling practices at HCAT.

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United States of America v. Healthcare Associates of Texas LLC, (N.D. Tex. 2024).

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