FCA SettlementOctober 28, 2026·6 min read

Negril to pay $1.8M to settle Medicaid NPI billing allegations; OIG lists it under heightened scrutiny

A Virginia mental health provider agreed to pay $1,817,910.60 to resolve allegations that it billed Medicaid under its own NPI for services another, unenrolled company provided. HHS-OIG now lists Negril under heightened scrutiny.

FCA SettlementMedicaidNPIHHS-OIGprovider enrollment

By the HCC Buddy Coding Team

Published October 28, 2026

Billing desk with balance scales, two blank provider ID cards, and a closed claims folder, for a Medicaid NPI settlement — Negril Incorporated agreed to a $1,817,910.60 settlement over Virginia Medicaid claims the government alleged were billed under the wrong provider's NPI. — Illustration: HCC Buddy

Key Takeaways

→On October 19, 2026, the U.S. Attorney's Office for the Western District of Virginia announced that Negril Incorporated agreed to a $1,817,910.60 civil settlement to resolve False Claims Act and Virginia Fraud Against Taxpayers Act allegations.
→The government alleged that from January 2021 through May 2022, Negril billed Virginia Medicaid under its own NPI for mental health skill-building services that a different company provided, and that the other company had no NPI of its own, was not credentialed through the Virginia Department of Behavioral Health and Developmental Services, and was not enrolled as a Medicaid provider.
→According to the government, Negril sent 75 percent of the Medicaid reimbursement for those claims to the other company and kept the remaining 25 percent. The U.S. Attorney's Office says the claims are allegations only, with no admission of wrongdoing and no determination of liability.
→HHS-OIG lists Negril Incorporated under heightened scrutiny, with the entry marked "Refused on September 21, 2026." OIG's 2016 exclusion criteria say OIG considers parties that refuse a corporate integrity agreement a greater continuing compliance risk than parties that sign one.
→OIG's fiscal year 2026 risk spectrum for False Claims Act settlements, updated October 21, 2026, places 5 settlements in the heightened scrutiny category, up from 2 in fiscal year 2025, alongside 7 exclusions, 17 corporate integrity agreements, 166 no further action, and 11 self-disclosures.

On October 19, 2026, the U.S. Attorney's Office for the Western District of Virginia announced that Negril Incorporated, a mental health services provider incorporated in Virginia, agreed to a $1,817,910.60 civil settlement. The settlement resolves allegations that Negril and its owners caused false claims to be submitted to Virginia Medicaid. A day later, HHS-OIG's What's New page listed an update to its heightened scrutiny entry for Negril, a category OIG used in 5 False Claims Act settlements in fiscal year 2026, compared with 17 corporate integrity agreements.

What the government alleged

The government alleged that from January 2021 through May 2022, Negril billed Virginia Medicaid under its own National Provider Identifier (NPI) for certain mental health skill-building services. According to the release, the company that actually provided those services didn't have its own NPI, wasn't credentialed through the Virginia Department of Behavioral Health and Developmental Services, and wasn't enrolled as a Medicaid provider.

Under the billing arrangement the government describes, Negril submitted the claims, sent 75 percent of the Medicaid reimbursement to the other company, and kept the remaining 25 percent. The U.S. Attorney's Office says the claims resolved by the settlement are allegations only, and there has been no admission of wrongdoing and no determination of liability.

Item	Detail
Settling party	Negril Incorporated, Danville, Virginia
Settlement amount	$1,817,910.60, payable over five years (per OIG)
Laws cited	False Claims Act and Virginia Fraud Against Taxpayers Act
Program	Virginia Medicaid
Services named	Mental health skill-building services
Period alleged	January 2021 through May 2022
Alleged payment split	75 percent to the other company, 25 percent kept by Negril
Complaint filed	June 12, 2026
Case	United States et al. v. Negril Incorporated et al., No. 6:26-cv-00066 (W.D. Va.)

The U.S. Attorney's Office says the settlement came from a coordinated effort with HHS-OIG, the HHS Office of Counsel to the Inspector General, and the Medicaid Fraud Control Unit of the Virginia Attorney General's Office. According to the release, First Assistant United States Attorney Robert N. Tracci and Special Agent in Charge Maureen Dixon of the U.S. Department of Health and Human Services announced the resolution, and Assistant U.S. Attorney Matthew G. Howells and Assistant Attorney General Kimberly M. Bolton of the Virginia Medicaid Fraud Control Unit handled the matter.

What heightened scrutiny means

When OIG settles a health care fraud case, its Fraud Risk and Heightened Scrutiny page says it usually takes one of five approaches: exclusion, heightened scrutiny, integrity obligations, no further action, or, for a good faith and cooperative self-disclosure, a release with no integrity obligations. OIG's April 18, 2016 exclusion criteria rank those approaches from highest to lower risk in that same order.

The 2016 criteria explain that OIG sometimes decides a corporate integrity agreement is necessary, but the party refuses to agree to one. In those cases, OIG weighs whether to pursue exclusion or to use other administrative tools to monitor the party, which it calls unilateral monitoring. OIG says it has referred such parties to CMS contractors for claims reviews, and has audited, evaluated, and investigated parties after fraud settlements when no integrity provisions were in place.

OIG's entry for Negril shows "Heightened Scrutiny," the note "Refused on September 21, 2026," and a duration of five years. Heightened scrutiny isn't the same as exclusion. OIG's risk spectrum places it between exclusion, at the highest-risk end, and integrity obligations.

Two blank provider ID cards beside a closed claims folder on a billing desk — The government's allegations turn on whose NPI went on the claims and who actually furnished the services.

How Negril fits OIG's fiscal year 2026 numbers

OIG updated its risk spectrum for False Claims Act settlements on October 21, 2026. The fiscal year 2026 chart shows more heightened scrutiny settlements than the year before, though they're still a small share of the total.

Risk spectrum category	FY 2025 settlements	FY 2026 settlements
Exclusion	9	7
Heightened scrutiny	2	5
Corporate integrity agreements	22	17
No further action	202	166
Self-disclosure	7	11

Why the billing NPI matters on your desk

This case isn't about diagnosis codes. The release doesn't name any ICD-10-CM codes, HCCs, or procedure codes. The allegations are about who furnished the services and whose NPI went on the claims.

CMS describes the National Provider Identifier as a HIPAA Administrative Simplification Standard: a unique 10-digit identification number for covered health care providers. CMS says covered health care providers, health plans, and health care clearinghouses must use NPIs in the administrative and financial transactions adopted under HIPAA.

In the government's account, the claims went out under Negril's NPI, while the services came from a company that, according to the release, had no NPI, credential, or Medicaid enrollment of its own. That's the kind of mismatch a billing or coding desk can catch early. If another company's staff deliver services that go out under your organization's NPI, that arrangement belongs in front of your compliance team before the next batch of claims goes out.

The other end of OIG's spectrum is worth knowing, too. The 2016 criteria say OIG will usually release its exclusion authority without requiring integrity obligations when a party self-discloses the conduct to OIG cooperatively and in good faith.

Key dates

Date	What happened
January 2021 through May 2022	Period of the alleged billing
June 12, 2026	Government filed its civil complaint
September 21, 2026	Date on OIG's heightened scrutiny entry ("Refused on")
October 19, 2026	U.S. Attorney's Office announced the settlement
October 20, 2026	OIG's What's New page listed the updated Negril entry
October 21, 2026	OIG updated its FY 2026 risk spectrum page

What coders should do now

1Pull a sample of recent claims and identify the billing provider and who furnished each service. Ask compliance to verify that any arrangement involving another company's staff meets the applicable payer's enrollment, credentialing, and billing requirements.
2If another company's staff deliver services that are billed under your organization's NPI, raise the arrangement with your compliance team before more claims go out.
3When you use this case in billing or enrollment training, present the government's account as allegations, since the settlement includes no admission of wrongdoing and no determination of liability.
4If a review turns up claims that shouldn't have gone out, take them to compliance and ask about OIG's self-disclosure process, which sits at the lowest-risk end of OIG's risk spectrum.

Frequently Asked Questions

How much did Negril agree to pay to settle the Virginia Medicaid case?

Negril Incorporated agreed to a $1,817,910.60 civil settlement, announced on October 19, 2026, by the U.S. Attorney's Office for the Western District of Virginia. OIG's entry for Negril says the amount is payable over five years.

Did Negril admit to billing Medicaid improperly?

No. The U.S. Attorney's Office says the claims resolved by the settlement are allegations only, and that there has been no admission of wrongdoing and no determination of liability.

What does it mean when OIG puts a provider under heightened scrutiny?

OIG's 2016 exclusion criteria describe cases where OIG decides a corporate integrity agreement is necessary but the party refuses to agree to one. OIG then weighs exclusion or other administrative tools, such as referrals to CMS contractors for claims reviews, and it considers the party a greater continuing compliance risk.

Does heightened scrutiny mean Negril is excluded from Medicaid?

OIG lists Negril under heightened scrutiny, which is a separate category from exclusion. On OIG's risk spectrum, exclusion is the highest-risk approach and heightened scrutiny is the next step down.

Does the Negril settlement involve ICD-10-CM codes or HCCs?

The release doesn't name any ICD-10-CM codes, HCCs, or procedure codes. The allegations are about who furnished mental health skill-building services and whose NPI was used to bill Virginia Medicaid for them.