AIDS Healthcare Foundation to pay $1.44M; DOJ alleges MA diagnosis deletes sat for years

On October 6, 2026, the Justice Department announced that AIDS Healthcare Foundation (AHF), a Los Angeles nonprofit, agreed to pay $1.44 million to resolve False Claims Act allegations tied to Medicare Advantage diagnosis codes. The dollar figure is small next to recent MA settlements. The workflow DOJ describes is not: coders flagged codes for deletion, and according to the government, the deletes waited years.

What DOJ announced

According to the DOJ Office of Public Affairs release, AHF agreed to pay $1.44 million to resolve allegations that it violated the False Claims Act by submitting or failing to delete false or invalid diagnosis codes to increase its Medicare Advantage payments. DOJ says AHF's Managed Care Division, doing business as Positive Healthcare Partners, operated special needs MA plans for Medicare beneficiaries with HIV in Florida, Georgia, and California.

DOJ states the claims resolved by the settlement are allegations only and there has been no determination of liability.

The delete backlog DOJ describes

This case is not about a review that only added codes. DOJ says that beginning around 2017, AHF's risk adjustment coders did run chart reviews to find inaccurate or unsupported diagnosis codes for deletion, and kept "Delete Research" spreadsheets listing codes they identified as potentially lacking support in the medical record but needing further research.

The government's allegation is about what happened next. According to DOJ, AHF knew it was required to investigate and delete inaccurate and unsupported diagnosis codes within 60 days, but failed to timely investigate and delete them. DOJ alleges AHF did not delete most of the codes on those spreadsheets until 2024 or 2025, after it was on notice that the codes potentially lacked support and only after being notified of the United States' investigation.

For a risk-adjustment desk, that is the line to notice. In the government's account, the flagged codes put AHF on notice that they potentially lacked support long before most were deleted. A delete flag that sits in research is not a finished delete.

The B20 allegation: no face-to-face record

The United States further alleges that for payment year 2017, AHF knowingly submitted diagnosis codes for HIV (ICD-10 B20) where the diagnosis was not documented in any medical record for a face-to-face visit. DOJ describes that as a violation of CMS requirements that all diagnosis code submissions must be documented as a result of a face-to-face visit.

Unlike the Independence Blue Cross release, which named no codes, this one names a code. It names it as an allegation, not as a finding, and it does not say how many B20 submissions were involved.

Where B20 and Z21 sit for a coder

The ICD-10-CM side of HIV is settled guidance, and it explains why a B20 allegation is about the record, not the code choice. Section I.C.1.a of the FY 2027 ICD-10-CM Official Guidelines says:

In CMS's 2027 initial ICD-10-CM mappings, both B20 and Z21 map to CMS-HCC V28 HCC 1 (HIV/AIDS). So picking between them does not move the HCC. What the government alleges is missing here is the face-to-face record itself, and neither code is supported without one. Z21 is not a fallback for an undocumented B20.

How the case surfaced

The settlement resolves a qui tam lawsuit filed under the False Claims Act's whistleblower provisions by a former AHF risk adjustment coder. The case is captioned *United States ex rel. Irons v. AIDS Healthcare Foundation d/b/a Positive Healthcare Partners*, No. 23-cv-2160, in the U.S. District Court for the Central District of California. DOJ says the relator will receive $259,200 as her share of the federal recovery.

DOJ also says AHF received credit under its guidelines for disclosure, cooperation, and remediation (Justice Manual § 4-4.112). According to the release, AHF cooperated in the investigation, enhanced its compliance program, and proactively remediated during the investigation by submitting deletes for diagnosis codes that, based on review of medical records, were not supported.

The matter was handled by the Civil Division's Commercial Litigation Branch, Fraud Section, and the U.S. Attorney's Office for the Central District of California, with assistance from HHS-OIG.

What this does not change on the claim

The release does not change ICD-10-CM indexing, the HIV coding guidelines, or CMS-HCC V28 mappings, and it does not announce a RADV schedule. It does not publish a list of the deleted codes other than the B20 allegation. It is an enforcement resolution about alleged diagnosis-data integrity: what an MA organization does once its own coders flag a code as unsupported.

It sits next to the Independence Blue Cross $22.5M settlement and the Aetna $117.7M settlement in HCC Buddy's MA enforcement coverage. Those cases name different defendants and different alleged patterns; do not read AHF as a rewrite of either.

Where coders should tighten this week

Pull your open delete queue, whatever it's called in your shop, and age it. Every flagged code should have an owner, a research due date, and a documented outcome: deleted, or kept with the record support written down. If items have been sitting for months, escalate them through compliance now rather than waiting for the next sweep. Use MEAT criteria as the support test and the HCC 1 reference when you need the V28 mapping for an HIV code.