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Ray Anthony Shoulders, Amniotic Fluid Injection Scam, Texas 2023

Fort Worth, TX – A pain management physician’s assistant is facing federal charges for a brazen scheme to defraud Medicare out of over half a million dollars. Ray Anthony Shoulders, 36, allegedly injected patients with amniotic fluid for unapproved pain treatment, then systematically billed the government for a more expensive, legitimately reimbursable product he wasn’t using. The feds say it was a calculated con to line the clinic’s pockets, preying on vulnerable patients desperate for relief.

According to the indictment, Shoulders, working at a Fort Worth clinic, administered the injections claiming they were covered by Medicare. This was a lie. The FDA has not approved amniotic fluid for pain management, and Medicare explicitly denies coverage for the procedure, deeming it medically unnecessary. The scam involved two products: “Cell Genuity,” which Medicare wouldn’t pay for, and “Fluid Flow,” which it would – but only for wound care.

Initially, Shoulders attempted to have patients pay $800+ out-of-pocket for the Cell Genuity injections. When patients balked at the cost and questionable effectiveness, he allegedly switched tactics. He continued administering Cell Genuity, but started billing Medicare using the unique billing code (Q4206) reserved for Fluid Flow, the wound care product. This allowed the clinic to pocket roughly $1,200 per cubic centimeter injected – a substantial markup compared to the $400 they’d receive if they’d actually used Fluid Flow.

Federal prosecutors allege the clinic ramped up the number of injections to maximize profits. The scheme wasn’t about patient care; it was about exploiting a loophole and defrauding a system designed to help those in need. The FDA has issued warnings against using amniotic fluid for orthopedic conditions, chronic pain, or fatigue, highlighting the dangers and lack of scientific backing for such treatments. Medicare’s rules are clear: reimbursement follows FDA approval, and amniotic fluid isn’t approved for pain.

Shoulders has been indicted on one count of conspiracy to commit healthcare fraud and eleven counts of healthcare fraud. He made his initial appearance in federal court before U.S. Magistrate Judge Jeffrey Cureton. If convicted, he faces significant prison time and financial penalties. The feds are signaling they intend to aggressively pursue healthcare fraud cases, holding medical professionals accountable for exploiting the system.

This case underscores the persistent threat of healthcare fraud and the lengths to which some providers will go to enrich themselves at the expense of patients and taxpayers. The Northern District of Texas vows to continue its crackdown on these schemes, protecting both the integrity of Medicare and the safety of those seeking legitimate medical care. The investigation is ongoing, and further charges are possible.

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Key Facts

  • Category: Fraud & Financial Crimes

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