Comphrensive Pain Specialists was once one of the largest pain management companies in the nation.

The Department of Justice will accuse the company of fraud and false claims in an upcoming lawsuit.

One of the CPS owners is Sen. Steve Dickerson, R-Nashville.

Federal and state prosecutors are moving to file lawsuits accusing Tennessee Sen. Steve Dickerson and other owners of a massive pain management company of defrauding the government with years of unjustified tests, dishonest billing and forged documents.

Their company, Comprehensive Pain Specialists, or CPS, allegedly profited so much from questionable drug tests that a corporate executive once said urine samples "smelled like money," according to newly unsealed federal court records.

Prosecutors revealed in those court records they plan to sue CPS by incorporating allegations from seven whistleblowers who filed secret complaints against the company over the past three years. Five of the whistleblowers are former employees who say they were fired from CPS after discovering wrongdoing within the company.

All allegations are civil. Prosecutors have not announced any intention to pursue criminal charges against CPS or its owners.

Dickerson, R-Nashville, an anesthesiologist who co-founded and co-owned CPS, will be a named defendant in at least one allegation, court documents state. Dickerson did not immediately respond to an email asking for comment on Tuesday night and declined to comment on CPS when questioned about the company earlier this month.

Other known defendants will include former CPS CEO John Davis, who was recently convicted of health care fraud in another case, and CPS co-owners Dr. Peter Kroll, Dr. Richard Muench and Dr. Gilberto Carrero.

CPS was one of the largest pain management chains in the nation. The company once operated about 60 clinics across 11 states from its headquarters in Brentwood, but shut down last summer with little warning to patients and employees.

The 5 schemes feds allege against CPS:

Both federal and state attorneys plan to file a detailed complaints against CPS in the next three months. The court documents unsealed Tuesday say the lawsuits will accuse of the company of at least five schemes in violation of the False Claims Act:

CPS allegedly pressured employees to conduct unnecessarily expensive urine tests on patients so it could inflate billings to Medicare and Medicaid. CPS conducted “full panel” drug tests on every patient at every visit despite cheaper tests being standard practice once a patient becomes a regular at the clinic. CPS incentivized doctors to order the tests by paying them a share of laboratory revenue.

CPS allegedly followed a similar model with genetic and psychological tests, which were ordered with unjustifiable frequency merely to increase profits. Nurse practitioners and physicians’ assistants were paid bonuses of $5 to $25 for every test they ordered.

CPS allegedly allowed doctors and nurse practitioners to perform medical services in states where they weren’t licensed or at hospitals where they weren’t credentialed, then forged documents to make it appeared those services had been performed by Kroll, the company medical director. Kroll’s signature was allegedly forged by copy-and-pasting it onto documents, and one whistleblower alleges she did so up to 45 times a day.

CPS treated patients with acupuncture devices known as “P-Stims” that were not covered by Medicare and Medicaid, but then billed the government as if they were using a completely different device called an "implantable electroneutral simulator."

CPS allegedly “upcoded” visits with patients – pretending the visits were longer and more complex than they really were – so they could receive higher reimbursement rates from government insurance. CPS memos supposedly threatened that medical staff would loses bonuses or face disciplinary action if they documented visits in a way that led to lower reimbursement.

CPS INVESTIGATION:Who are the 7 whistleblowers?

Health care fraud cases often originate with whistleblower lawsuits that are filed under seal against a company that is accused of defrauding the government. Government prosecutors intervene in the lawsuit if they feel the claims are legitimate.

In the CPS case, prosecutors decided to adopt allegations from seven whistleblowers in a single consolidated complaint. In light of this decision, U.S. District Court Judge Aleta Trauger on Tuesday ordered the whistleblower suits unsealed and told the state and federal government to file their consolidated lawsuits within 90 days.

Jerry Martin, a former U.S. Attorney who represents one of the former CPS employees, said the case illustrates the vital role whistleblowers play in protecting taxpayer money.

"We are extremely grateful to the U.S. Attorney’s Office and the federal investigators who have put in countless hours to investigate these claim," Martin said. "We look forward to continuing to work with the government on this matter."

David Boling, a spokesman for the U.S. Attorney's Office for the Middle District of Tennessee, confirmed Wednesday morning that prosecutors would pursue the whistleblower allegations against CPS. Boling said he could neither confirm nor deny "the possibility of criminal charges related to the investigation."

CPS:Pain clinic CEO inflated Medicare billings, then bragged about it, feds say

Urine testing ‘smells like money’

Of all the CPS allegations revealed on Tuesday, court records go into most detail about the exorbitant drug tests.

Four whistleblowers alerted to the feds to the alleged scheme, and it may be the accusation that was most costly to the government. Every day, CPS appears to have billed the government for hundreds of drug tests at its lab in Brentwood when it could have performed simpler tests, without using a lab, at a fraction of the cost.

The questionable drug tests were also spotlighted in a 2017 investigation by Kaiser Health News that revealed CPS billed Medicare at least $11 million for drug tests alone in 2014. Four CPS employees were among Medicare’s top drug test billers in the entire nation that year.

More details come from whistleblower complaint filed by Scott Steed, who claims he toured the Brentwood lab alongside CPS executives. During the tour, Sneed said he commented on the “overpowering and unpleasant smell of urine.”

“To me, it smells like money,” an executive responded, according to Steed’s complaint.

The company’s heavy use of urine tests is further documented in another whistleblower complaint from Dr. Suzanne Alt, who worked at a CPS clinic in Missouri in 2015.

Alt claims that CPS employees were “strongly encouraged to order full panel urine drug screens on each patient, every time, despite the patient's history, compliance, and risk.” CPS practitioners sent about 20 urine samples to the lab a day, each, Alt said.

Alt said she later questioned her supervisor why the company didn’t use cheaper tests that did not require the lab. The supervisor told her to “test the CPS way,” and about one month later, she was fired.

Bribes, conflict of interest and angry patients

The court documents unsealed Tuesday are the first to allege wrongdoing by Dickerson, but they are far from the first accusation against CPS.

When CPS abruptly closed its clinics last year, numerous patients reported they received little notice and were left scrambling to find a new doctor before their prescriptions ran out. This search was greatly exacerbated by CPS’s failure to give at least some patients copies of their medical records, making it exceptionally unlikely that another pain clinic would be willing to take them on as a patient.

Davis, who was CEO of CPS from 2011 to 2017, was also criminally charged with healthcare fraud and convicted of accepting bribes for patient referrals. Prosecutors said that Davis and another defendant, Brenda Montgomery, conspired to forge the signature of a dead patient so they could bill Medicaid in his name. Davis is scheduled in sentencing in August.

Davis’ prosecution also cast allegations on Kroll, although he was not charged with any crime. In court records filed shortly before Davis’ trial, prosecutors said that Kroll – identified only by his initials – had a conflict of interest over psychological evaluations that were mandated for CPS patients. Kroll also worked for the company that performed the evaluations, and benefited from his own referrals.

Kroll and Muench did not respond to messages left at their offices on Wednesday. Contact information for Guerrero could not be located. Davis' attorney did not respond to a request for comment.

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Brett Kelman is the health care reporter for The Tennessean. He can be reached at 615-259-8287 or at brett.kelman@tennessean.com. Follow him on Twitter at @brettkelman.