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Dynamic Chiropractic – October 21, 2004, Vol. 22, Issue 22

Are Federal Investigators After UnclePaul?

Doctors Confirm They Have Been Contacted

By Editorial Staff
Doctors involved with the UnclePaul Chiropractic Business Training corporation confirm that they have been contacted by investigators from the U.S. Department of Justice, the U.S. Attorney's Office and the U.S. Department of Health and Human Services' Office of Investigations. According to these sources, federal investigators initially contacted some of them as early as the beginning of May 2004.

The investigators appear to be contacting many of the doctors who are operating, or at one time operated, UnclePaul clinics. While it is unlikely that they will contact all 100-plus clinic operators, at least eight have reportedly already been contacted.

According to sources, the federal investigators' main concerns appear to be centered on alleged Medicare, Medicaid and Stark law violations. Stark laws involve referral of patients to businesses with common ownership interests with the clinic.

Michael Schroeder, Esq., former attorney for the California Board of Chiropractic Examiners, made these comments about this situation:

"It's not unusual to see federal investigators involved in a high-profile case that could potentially involve Medicare, Medicaid or Stark law violations, particularly when more than 100 offices may be included. What will likely happen is that the investigators will contact only a portion of the chiropractic offices involved and only notify the remaining offices once legal action is taken.

"Those doctors who are operating those offices would be well-advised to seek legal counsel immediately. Their greatest opportunity to effect their situation is between now and the time when the federal investigators complete their investigation, which appears to be coming soon.

"It is not possible to predict whether the federal investigators will seek civil actions or criminal prosecutions. That is usually something that is determined at the completion of their investigation, based upon their findings.

"Thus far, there has been no mention of third-party-payer investigators. It would not be unusual to see a number of health insurance companies get involved if they determine that they may have overpaid some of these clinics."

In the Sept. 27 issue, we reported that Jeffrey Miller, DC, had filed an 18-page complaint with the Kentucky Board of Chiropractic Examiners against UnclePaul and its owner, Dr. Paul Hollern, 1, 2 alleging "multiple violations of Kentucky laws governing the practice of chiropractic." Dr. Miller served as the COO for UnclePaul from Oct. 1, 2003, until Jan. 8, 2004. The complaint alleged numerous violations of state statutes in up to 20 states.

More information is likely forthcoming regarding this high-profile case. DC will report further as the situation develops.


  1. UnclePaul accused. Dynamic Chiropractic, Sept. 27, 2004:
  2. The entire 18-page complaint appears online at
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