Dr. Darrell Hall Indictment
Dr. Darrell Hall Indictment
Dr. Darrell Hall Indictment
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21U.S.C. §§841(a)(l),(b)(l)(C)&
DARRELL A. HALL, 846; 18 U.S.C. § 1347; 26 U.S.C. §
7202
Defendant.
GENERAL ALLEGATIONS
1. DARRELL A. HALL was licensed under the laws of the State of Ohio to practice
medicine.
3. DARRELL A. HALL operated his medical practice under the name "EDM Health
Services, LLC."
4. DARRELL A. HALL was registered as a Medicaid Provider with the State of Ohio,
Case: 3:12-cr-00385-DAK Doc #: 1 Filed: 08/20/12 2 of 4. PageID #: 2
5. The State of Ohio Medicaid program provides free health benefits to qualified low-
COUNT 1
NARCOTICS CONSPIRACY
Beginning on or about August 25, 2008, through May 14, 2009, in the Northern District
of Ohio, Western Division, DARRELL A. HALL, defendant herein, and others known and
unknown, did knowingly, intentionally and unlawfully combine, conspire, confederate and agree
to commit offenses against the United States, that is, to knowingly, intentionally and unlawfully
distribute prescription controlled substances, outside the course of usual medical practice and for
no legitimate medical purpose, in violation of Title 21 United States Code Section 841(a)(l), to
All in violation of Title 21, United States Code Sections 841(a)(l), (b)(l)(C) and 846.
COUNT2
HEALTH CARE FRAUD
Scheme to Defraud:
The defendant, DARRELL A. HALL, as the sole proprietor of EDM Health Services,
LLC, unlawfully and fraudulently engaged in "upcoding" by billing the Ohio Medicaid plan
under code 99215, which requires at least two of the following three components: a
complexity; when in fact he should have billed no greater than code 99213, which requires at
least two of the following three components: an expanded problem focused history, an expanded
problem focused examination, and/or medical decision making of low complexity. In addition,
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DARRELL A. HALL unlawfully and fraudulently billed the Ohio Medicaid Plan for two office
Offense:
Between on or about January 12, 2007, to on or about December 9, 2009, in the Northern
District of Ohio, Western Division, the defendant, DARRELL A. HALL, knowingly and
willfully executed and attempted to execute the scheme and artifice to defraud set forth in the
above paragraph, to obtain, by means of materially false and fraudulent pretenses, representations
and promises, money and property in the amount of $78,113.75, said money and property being
owned by and under the custody and control of the Ohio Medicaid Fund, a health care benefit
program as defined in Title 18, United States Code, Section 24(b), in connection with the
COUNTS 3-14
FAILURE TO ACCOUNT FOR AND PAY OVER EMPLOYMENT TAX
December 2010, in the Northern District of Ohio, Western Division, the defendant, DARRELL
A. HALL, as sole proprietor of EDM Health Services, LLC, did willfully fail to truthfully
account for and pay over to the Internal Revenue Service all of the federal income taxes withheld
and Federal Insurance Contributions Act ("FICA") taxes due and owing to the United States, to
wit, $97,384.88, on behalf of EDM Health Services, LLC, and its employees, for each of the
following quarters, with each calendar quarter constituting a separate count of this Information:
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$6,721.18
$8,859.60
$9,401.97
$12,455.32
$10,820.85
$9,653.56
9 03/2009 $9,085.39
10 06/2009 $7,651.02
11 03/2010 $5,916.22
12 06/2010 $6,352.99
13 09/2010 $4,434.11
14 12/2010 $6,032.87
STEVEN M. DETTELBACH
UNITED STATES ATTORNEY
.VADUSTTN
Attorney in Charge, Criminal Division
Toledo Branch Office
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Defendant )
WAIVER OF AN INDICTMENT
I understand that I have been accused of one or more offenses punishable by imprisonment for more than one
year. I was advised in open court of my rights and the nature of the proposed charges against me.
After receiving this advice, I waive my right to prosecution by indictment and consent to prosecution by
information.
Date:
Defendant's signature
Judge's signature