No Halo News · Sourced development
AIDS Healthcare Foundation settles federal allegations over unsupported Medicare Advantage diagnosis codes for $1.44 million
The U.S. Department of Justice announced that AIDS Healthcare Foundation agreed to pay $1.44 million to resolve False Claims Act allegations involving its Positive Healthcare Partners Medicare Advantage plans. The government alleged that, for payment years 2017 through 2023, the nonprofit failed to timely investigate and delete diagnosis codes that were inaccurate or unsupported by medical records. DOJ also alleged that certain 2017 HIV diagnosis codes lacked documentation from a face-to-face visit. The settlement resolves allegations only and contains no determination of liability. DOJ credited the organization for cooperating, improving its compliance program and deleting unsupported codes during the investigation.
Status matters. This page records a sourced development, not a completed No Halo investigation. An allegation is not a finding. Dismissals, settlements, judgments, corrections and final outcomes remain distinct.
Donor relevance
Why this matters
The matter concerns the accuracy of information used to calculate federal Medicare payments. It also documents concrete remediation: DOJ said the nonprofit cooperated, strengthened compliance and submitted corrections for unsupported diagnosis codes.
Attribution
Who reported or established this
The allegations were made by the U.S. Department of Justice in resolving a whistleblower action filed by former AHF risk-adjustment coder Donna Irons. The description of remediation and cooperation also comes from DOJ.
Evidence limits
What remains unverified
No Halo has not independently reviewed the underlying medical records, established the accuracy of each disputed code, determined intent or calculated any excess reimbursement. The settlement did not adjudicate liability.
Right of reply
Organization response
AIDS Healthcare Foundation said it appreciated the opportunity to resolve the allegations amicably. It said the identified weaknesses did not result from bad intent, emphasized its cooperation and proactive remediation, and said it used the process to strengthen its compliance program.
Classification
How No Halo records this event
Event type: Settlement. Current state: Resolved. No Halo preserves the current procedural state rather than treating every mention as a finding.
Published October 6, 2026 · Last verified October 8, 2026. See an error or a later outcome? Submit a correction or right of reply.