A network of North Texas urgent care and primary care clinics called Heal 360, along with its owner, has agreed to pay $20 million to resolve allegations that it billed the federal government for complex medical visits that patients never actually received — when, in reality, most of them simply got a nasal swab for a COVID-19 test.
Heal 360 Urgent Care PLLC and Heal 360 Primary Care PLLC, along with owner Dr. Mohammed Amer Mohiuddin, agreed to resolve False Claims Act allegations that they submitted or caused the submission of false claims to the Health Resources and Services Administration's COVID-19 Uninsured Program, according to the Justice News. The government alleged the companies knowingly submitted false claims for evaluation and management services that were never actually performed on patients. From January 1, 2021, through March 23, 2022, Heal 360 allegedly billed the program for higher-paying Level 3 and Level 4 evaluation and management visits when patients at walk-up and drive-through sites in Texas only received routine nasal swab specimen collection, according to Becker's ASC.
How the Alleged Scheme Worked
Under federal guidelines in place during the public health emergency, routine COVID-19 specimen collection was supposed to be billed under CPT code 99211, a code reimbursed at a significantly lower rate than high-level office visits, the outlet's report notes. CPT 99211 was designated by CMS specifically for low-complexity specimen collection performed by clinical staff — not for the kind of in-depth physician evaluation that Level 3 and Level 4 billing codes are meant to cover.
To support the inflated claims, Heal 360 and Dr. Mohiuddin allegedly used overseas remote scribes to create template-generated medical records that fabricated patient medical histories and physical examinations, the same outlet reports. Dr. Mohiuddin was listed as the rendering physician on hundreds of thousands of claims even though he did not examine or treat patients at the temporary testing locations, per the report — a detail that illustrates just how organized the alleged record falsification was, since healthcare regulations require rendering physicians to directly provide or supervise the services they bill for.
A Whistleblower Lawsuit Set It in Motion
The settlement resolves two whistleblower qui tam lawsuits, one filed in the U.S. District Court for the Eastern District of Texas and one in the Northern District of Texas, according to the Department of Justice. The False Claims Act allows private individuals to file such suits on behalf of the federal government and potentially receive a portion of any recovered funds.
The alleged billing scheme's timeline lines up with when the money ran dry: the HRSA COVID-19 Uninsured Program officially stopped accepting claims for COVID-19 testing and treatment on March 22, 2022, after its dedicated multi-billion-dollar federal funding allocation was fully exhausted, according to the Health Resources and Services Administration. Congress had created the program to reimburse healthcare providers for testing and treating patients who lacked insurance coverage, and it paid out claims nationwide until that funding ran out.
Part of a Wider North Texas Pattern
Heal 360 is not the only North Texas provider involved in a COVID-19 billing settlement. In May 2025, Collin County physician Dr. Samad Khan and SK Primary Care agreed to pay $3.5 million in a separate settlement.
The Heal 360 settlement also lands just days after another major HRSA-related resolution: on September 30, healthcare provider Signal Diagnostics LLC agreed to a $20.5 million False Claims Act settlement with the Department of Justice over alleged overpayments and improper claims submitted to the same uninsured testing program, according to Govly. Civil settlements like these typically resolve allegations without any formal admission of liability by the companies involved.
Heal 360's Footprint and Legal Exposure
Heal 360 operates urgent care and primary care clinics, including in Plano and Garland.
Under the False Claims Act, entities found liable for submitting false claims face treble damages plus statutory civil monetary penalties ranging between $13,946 and $28,619 per false claim as of 2025, according to Paul Padda Law. That exposure helps explain why a civil settlement of this size — reflecting the sheer volume of claims submitted across Heal 360's North Texas locations — made financial sense for the companies even without an admission of fault.
Fitting a National Enforcement Push
The Heal 360 case is one piece of a much larger federal effort to address pandemic relief fraud. In April 2023, federal prosecutors announced a nationwide coordinated law enforcement action charging 18 defendants across nine federal districts in connection with almost $500 billion in alleged COVID-19 healthcare fraud. Cases involving the HRSA Uninsured Program were among those cited in the action.
Hoodline has tracked similar settlements before: in February 2025, urgent care provider CityMD agreed to pay $7 million to repay patients for improper COVID-19 test charges and cancel additional medical debt. A separate, earlier federal settlement involving the HRSA COVID-19 Uninsured Program was $12 million. Taken together, the Heal 360, SK Primary Care and CityMD cases illustrate different disputes over pandemic-era COVID-19 testing and billing.
