An Anaheim woman has pleaded guilty to running a Medicare hospice fraud scheme that submitted more than $2.2 million in claims for patients who were not terminally ill or whose medical records did not support hospice eligibility.
Lynn Galbraith, 60, owned and operated Azure Hospice Care Inc. in Garden Grove. She pleaded guilty Aug. 27 to one count of health care fraud.
Federal prosecutors say Azure submitted approximately $2,266,694 in false Medicare claims. Medicare paid the company approximately $2,140,606 before the scheme ended.
Galbraith now faces up to 10 years in federal prison when she is sentenced Dec. 3, according to the U.S. Attorney’s Office for the Central District of California.
She Knew Some Patients Did Not Qualify for Hospice
Medicare hospice coverage depends on a physician certifying that a patient’s life expectancy is six months or less if the terminal illness follows its normal course.
According to Galbraith’s plea agreement, she knew some Azure beneficiaries were not terminally ill. In other cases, she knew their medical records did not contain sufficient evidence supporting the diagnosis and prognosis required for Medicare hospice benefits.
Prosecutors also said Galbraith did not routinely coordinate with the patients’ primary care physicians regarding their purported terminal conditions or prognoses.
Despite those deficiencies, she caused claims to be submitted representing the beneficiaries as eligible so Medicare would reimburse Azure.
One $6,600 Claim Illustrates the False Billing
Federal prosecutors highlighted an October 2022 claim involving one beneficiary. Galbraith admitted submitting a $6,600 claim for hospice services even though she knew the medical record did not contain sufficient documentation establishing that person’s Medicare hospice eligibility.
The individual claim was one example cited in her plea agreement rather than a separate fraud scheme. The Centers for Medicare & Medicaid Services says hospice certification must have a clinical basis supported by medical information and documentation consistent with a prognosis of six months or less.
She Controlled Azure Hospice for More Than Four Years
Galbraith was co-owner and operator of Azure Hospice Care from September 2019 until July 2022. She then became the Garden Grove company’s sole owner and remained in that role through February 2024.
Earlier federal charging records placed the fraudulent billing between April 2021 and February 2024. Her case was publicly announced in June as part of a broader federal health care fraud enforcement action in Southern California. The Department of Health and Human Services Office of Inspector General is investigating the case.
Medicare Paid More Than $2.1 Million Before the Scheme Ended
The amount Azure billed and the amount Medicare actually paid are different. Galbraith admitted responsibility for approximately $2,266,694 in false claims. Medicare reimbursed Azure approximately $2,140,606 on those claims.
U.S. District Judge John A. Kronstadt scheduled sentencing for Dec. 3. The health care fraud offense carries a statutory maximum sentence of 10 years, although the judge will determine Galbraith’s actual punishment.
Patients Can Help Detect Hospice Billing That Does Not Match Their Care
Medicare beneficiaries and their families can question hospice claims that do not match the care a patient actually received or a hospice enrollment they do not recognize. Medicare eligibility requires a qualifying terminal prognosis supported by clinical information, and beneficiaries who believe their records inaccurately describe them as terminally ill can raise the issue with Medicare or the provider involved.
Families should preserve Medicare notices, hospice paperwork, medical records and communications showing what care was actually provided. Dates, provider names and specific services can be particularly useful when reporting questionable billing. The HHS Office of Inspector General accepts complaints involving suspected fraud, waste and abuse in Medicare and other HHS programs.
Suspected Medicare fraud can also be reported by calling 1-800-447-8477. Reporting unexplained hospice claims can help investigators determine whether the problem is an isolated billing error or part of a broader pattern involving patients who were never eligible for the benefit.