Executive Brief Series: Insights on Recent OIG Enforcement Actions & Trends

Prosecution Against Unlicensed Nurse Points to Urgent Need for Continuous Credential Monitoring

Written by A. Michael Rosen, Esq. and Donna Thiel

In October 2022, the South Carolina Medicaid Fraud Control Unit (SCMFCU) arrested a 37-year-old South Carolina woman named Alyssa Beth Steele for working as a registered nurse despite not having a license. From January 2020 to June 2021, Steele practiced medicine at seven different nursing and assisted living facilities across Anderson, Greenville, and Pickens counties, SC.

According to the SCMFCU, Steele used a State of Georgia Board of Nursing license number belonging to someone else to gain employment at these facilities. However, the attorney general’s office found that at no point during her employment at these facilities did Steele have any certifications, qualifications, or training required for registered nurses.

In an official news release, the attorney general stated, “By holding herself out as having credentials she did not possess, Steele’s conduct resulted in a failure to provide adequate medical care and services to vulnerable adults and presented a substantial risk of causing physical or mental injuries to the residents under her care.”

Pursuant to federal regulations, the SCMFCU is authorized to investigate and prosecute any acts of Medicaid provider fraud. This includes abuse and neglect of Medicaid beneficiaries and the abuse, neglect, and exploitation of patients in nursing and assisted living facilities.

Steele is faced with the following charges:

  • Seven counts of Neglect of a Vulnerable Adult (carries up to 5 years in prison)
  • Five counts of Unlicensed Practice as a Registered Nurse (carries one year in prison or a maximum fine of $50,000)
  • One count of Financial Identity Fraud to Obtain Employment (carries a fine or imprisonment of up to 10 years)
  • One count of Obtaining Signature or Property Under False Pretenses, Value $10,000+ (carries a fine of up to $500 and up to 10 years in prison)

Prevent Fraud by Verifying Licenses Routinely

This prosecution points to the urgent need for healthcare organizations to verify and closely monitor their providers’ licenses. Donna Thiel, Chief Compliance Officer at ProviderTrust, said of the Steele case, “​​When I look at this, I think about how seven different places really failed to do just an initial, basic 101 license verification. This is another classic reason why, if you failed in your pre-hire process to do the appropriate credential verification, at least if you were doing monthly or even quarterly [checks], you would’ve caught this.”

Steele’s prosecution proves how vital it is for healthcare organizations to verify practitioner credentials on an ongoing basis routinely. If organizations only verify licenses upon hire, annually, or as an expiration date approaches, they could miss essential eligibility changes. Invalid and expired licenses can lead to providers committing healthcare fraud and risking patient safety.

Still, it begs the question of how seven different facilities were unable to catch Steele’s use of a borrowed license number. “I think the timeframe is really important,” Thiel went on to say. “This was during Covid. The rules in some of the states allowed reciprocity and allowed a lot of flexibility on the license because it was so hard to find staff. I’m not saying that this is an acceptable excuse for these providers, but I think that might be part of the story.”

Mike Rosen, Co-Founder of ProviderTrust, added, “​​We do know that when people’s budgets are cut short, or there are emergency actions or lack of funding, the fraudsters know that’s the time to come out.”

Include Provider Identity Verification in your Compliance Monitoring

To stay vigilant, healthcare organizations should go beyond the usual verification checks for providers’ licenses and begin verifying a provider’s actual identity as well. This should become an integral part of the license verification process.

“Have you gone back and re-verified every license?” Thiel asks. “Have you made sure that people have come in with their driver’s license and their social security card to confirm their identity? ​​Those are the things that these seven facilities are probably dealing with today– re-verifying and really trying to gather the trust of the families, patients, and residents that they’re caring for. That’s a tough place to be.”

For her numerous healthcare fraud charges, Alyssa Steele was arrested and booked into the Anderson County Detention Center in Anderson, SC. She was served separate charges from Anderson, Greenville, and Pickens counties. Local police and county sheriff’s departments provided additional assistance in this case, but the Attorney General’s office will prosecute all charges.

Simplify your License and Credential Verification Process

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