Case: 3:12-cr-00385-DAK Doc #: 1 Filed: 08/20/12 1 of 4.

PageID #: 1

Rirj.S. DISTRICT COL^T

HOr'UHERH DISTRICT 0l; WQ
TOLEDO

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF OHIO
WESTERN DIVISION

UNITED STATES OF AMERICA, INFORMATION

Plaintiff, 3-'12 CR 385

Criminal No.
v.

21U.S.C. §§841(a)(l),(b)(l)(C)&
DARRELL A. HALL, 846; 18 U.S.C. § 1347; 26 U.S.C. §
7202
Defendant.

The United States Attorney charges that: (VIAG. JUDGE

GENERAL ALLEGATIONS

At all relevant times herein:

1. DARRELL A. HALL was licensed under the laws of the State of Ohio to practice

medicine.

2. DARRELL A. HALL was also licensed by the Drug Enforcement Administration to

prescribe controlled substances in connection with his medical practice.

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

and was assigned Provider # 2102496.

5. The State of Ohio Medicaid program provides free health benefits to qualified low-

income residents of Ohio.

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

wit: 1,300 pills of 80 milligrams of Oxycodone, a Schedule II controlled substance.

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

comprehensive history, a comprehensive examination, and/or medical decision making of high

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

visits by the same patient on the same date.

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

payment for benefits, items, and services.

All in violation of Title 18, United States Code, Section 1347.

COUNTS 3-14
FAILURE TO ACCOUNT FOR AND PAY OVER EMPLOYMENT TAX

Beginning in or about March 2007, and continuing up to and including in or about

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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Count Tax Due Amount of Unpaid Tax

$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

All in violation of Title 26, United States Code, Section 7202.

STEVEN M. DETTELBACH
UNITED STATES ATTORNEY

.VADUSTTN
Attorney in Charge, Criminal Division
Toledo Branch Office
 Case: 3:12-cr-00385-DAK Doc #: 1-1 Filed: 08/20/12 1 of 1. PageID #: 5

AO455 (Rev. 01/09) Waiver of an Indictment

United States District Court

for the
Northern District of Ohio

United States of America ) "2 a "1 *} r\ n

v. ) Case No. • " 1 L OK
Darrell A. Hall )

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

Signature of defendant's attorney

Printed name of defendant's attorney

Judge's signature

Judge s printed name and title