The federal criminal information released as part of former lobbyist Rusty Cranford's June 7 guilty plea on bribery charges describes a Person 9 who worked for the nonprofit healthcare provider Preferred Family Healthcare and was associated with Cranford. This individual is not explicitly accused of criminal wrongdoing in the federal information on Cranford, but according to the government, Person 9 was involved in Cranford's efforts to seek policies that benefited PFH and other behavioral health providers.Person 9 was also affiliated with an advocacy organization for health providers that paid income directly from the dues providers were charged for membership to Person 9, Cranford and then-Sen. Jeremy Hutchinson, according to the federal information.
The description of Person 9 appears to match Robin Raveendran, the former PFH executive — and former longtime staffer at the state's Department of Human Services — who was arrested Thursday in a separate case, charged in Independence County with two felony counts of Medicaid fraud after an investigation by the state's Medicaid Fraud Control Unit.
PFH has a vast network of 47 service providers in Arkansas that has brought in tens of millions of dollars in Medicaid funding, state grants and contracts with the DHS. The nonprofit has not been charged with criminal wrongdoing, but it has been at the center of a number of indictments and pleas in federal corruption cases involving lobbyists and former Arkansas lawmakers, as well as the affidavit for Raveendran's arrest warrant on state charges. Cranford — also a former PFH executive — admitted to bribery, kickback and embezzlement schemes involving PFH funds in his plea agreement earlier this month. The federal charges against Cranford are not directly connected to the new charges against Raveendran, which involve alleged improper billing practices while he was at PFH — but the affidavit alleges that Cranford worked aggressively along with Raveendran to influence state policy in ways that would allow the alleged billing fraud scheme to continue. The DHS announced Friday that it was suspending Medicaid payments to PFH, and exercising contract termination clauses in existing contracts, after the Office of Medicaid Inspector General notified the department that it had determined that there was a credible allegation of fraud against PFH, based upon the affidavit for Raveendran's arrest.
Raveendran and Person 9
Shortly after Cranford's plea, on June 11, the Arkansas Times called Raveendran to ask about Person 9. Raveendran said that he was heading to a meeting and would call back. The following day, an attorney representing Raveendran, Jordan Tinsley, called and stated, "Mr. Raveendran has no comment on any of the ongoing matters related to Mr. Cranford or Mr. [Jeremy] Hutchinson at this time. I can neither confirm nor deny the identity of Person #9. The identity of various people that had business relationships with Mr. Cranford have not been publicly revealed by prosecutors, and the reason for that is that these people are uncharged and their reputations are at stake and they're deserving of privacy. ... The identity of those unnamed persons in the indictment are not revealed for a reason and out of respect for that reason, we can neither confirm nor deny anything related to that at this time." Tinsley did not return calls today asking for comment following Raveendran's arrest.
According to the federal information, Person 9 worked for PFH from March 23, 2014, to December 1, 2017, and was a "former Arkansas state employee." That closely matches, within one day, Raveendran's employment with PFH; according to the affidavit for his arrest warrant, he worked at PFH from March 24, 2014, through December 1, 2017. PFH confirmed that these dates were accurate. (Raveendran's LinkedIn page apparently shaved off a few months, stating that he worked from PFH from March 2014 through October 2017.)
Raveendran also matches the description of a "former state employee" — he previously worked for the DHS for around 28 years. From August 1984 to April 2003 he was senior audit manager; from May 2004 through February 2014, he was Program Integrity director. In 2013, his Program Integrity director position moved from the DHS to the Office of Medicaid Inspector General — the same office that determined Friday that there was a credible allegation of fraud against him.
Raveendran is executive director of the Alliance for Health Improvement (AHI), which represents mental health care providers in the state. The AHI is not listed as a client of the Cranford Coalition — Cranford's lobbying firm — on its disclosure filings. However, Raveendran clearly had a close working relationship with Cranford, which likewise matches the description of Person 9. In April of 2015, Raveendran joined the Cranford Coalition as "authorized personnel," as reported in an updated disclosure filing by the lobbying firm that year. In the Medicaid Fraud Control Unit affidavit, he is described as "one of Cranford's closest associates." The affidavit also states that PFH hired Raveendran on Cranford's recommendation and that Raveendran worked directly under Cranford at PFH.
Raveendran and Entity I
According to the federal information, Person 9 "employed Cranford as a lobbyist to represent the interests of health service providers." According to the Cranford Coalition's disclosure filings, the Arkansas Behavioral Health Providers Association (ABHPA) was a client of Cranford's during the relevant period. It is unclear whether Raveendran has any affiliation with ABHPA, although the group worked on many of the same issues as the Raveendran-led Alliance for Health Improvement. It is also possible that the AHI is Entity I in Cranford's plea. There is no public record of the group employing Cranford as a lobbyist, but the Medicaid Fraud Control Unit affidavit states that "the full scope of [Cranford and Raveendran's] relationship is the subject of an ongoing investigation involving multiple companies, including one of Raveendran's companies, Alliance for Health Improvement."
According to the federal information, Entity I "was a private 'provider' association focusing on community health." It was "formed to advocate for issues relating to 'providers' at the Arkansas state legislature and in state departments while also increasing communications between those entities." Entity I was associated with Cranford, employed as the group's lobbyist; with a state senator (now identified as Jeremy Hutchinson) "who was allegedly employed as their attorney"; and Person 9, "who organized the provider meetings and assisted in training, education, and policy making."
The federal information on Person 9 — teaming with Cranford and Hutchinson
If Person 9 is in fact Raveendran, the federal information depicts examples of how he worked with Cranford and Hutchinson to influence policy in ways that would benefit the bottom line for health care providers like PFH, as well as using a provider group to funnel money to them.
Providers paid dues of $5,000 and $10,000 per year for membership into Entity I. Cranford, Hutchinson and Person 9 all received a percentage of the membership dues in exchange for their work for Entity I — income that came directly from these provider dues, according to the federal information. Hutchinson was paid $8,125 by Entity I in early 2015, around the same time that he began receiving payments as an attorney from PFH affiliates.
On March 4, 2015, Person 9 sent an email to Hutchinson and Cranford regarding a statute that defined independent contractors as opposed to employees: "We need to file a shell bill to take care of this issue, it may be possible we should be able to work this out with Workforce, however, just to protect us we want to a shell bill." The email suggested a specific revision that would have been favorable to healthcare providers. Hutchinson filed the shell bill in 2015; a separate bill eventually enacted the requested change — "the same specific revision to Arkansas law as that forwarded to him by Person 9 and Entity I," according to the federal information.
A player at the Capitol
The news of Raveendran's arrest — and his apparent connection to separate activities described in the federal information on Cranford — will raise eyebrows at the Capitol, where Raveendran has been a major player in healthcare policy debates.
Raveendran, representing the AHI, was appointed by Governor Hutchinson to his Advisory Council on Medicaid reform in 2015 (Raveendran was also appointed by the governor to the Criminal Justice Task Force in 2015). Raveendran has been a vocal advocate on behalf of behavioral health providers, with a seat at the table on issues involving Medicaid managed care and payment reform. The Raveendran-led AHI, as well as Cranford's listed client, the Arkansas Behavioral Healthcare Providers Association, were both heavily involved in discussions with the legislative Health Reform Task Force. In February of 2016, AHI, ABHPA, and a third group, Mental Health Council of Arkansas, presented a plan for provider-proposed reforms and projected cost savings. In the summer of 2016, the task force recommended that DHS hold discussions with these three groups regarding certain rules and policy changes, at least some of which likely influenced the task force's final recommendations.
Raveendran and PFH
The activities described in both the information on Person 9 in Cranford's federal plea information and the affidavit for Raveendran's arrest warrant on state charges took place when Raveendran was working for PFH. The information in Cranford's plea suggests that Cranford was highly successful — with the help of various insiders, including Person 9 — at influencing state policy in a way that benefited PFH. The affadavit for Raveendran's arrest warrant states that Raveendran and Cranford also had considerable success in fighting "to keep the Medicaid vulnerabilities [Raveendran] exploited in place" to carry out the alleged billing fraud scheme.
PFH did not respond to queries sent by the Arkansas Times on June 11 asking whether Raveendran left the company on his own or had his employment terminated, and asking whether his departure was connected to any of the wrongdoing described in Cranford's plea.
Once Raveendran was arrested, PFH issued a new statement Friday, distancing the nonprofit from its former employee and confirming that he was terminated:
"As the documents charging Robin Raveendran clearly show, Preferred Family Healthcare has been cooperating extensively with this investigation. Raveendran was let go from PFH in 2017. PFH continues to work with government authorities to uncover misconduct by several former leaders and employees of the organization. We are committed to cooperating and providing any information which will ensure that any individual whose actions may have violated the law are held accountable.
"Sadly, these charges show a concerted effort to deceive PFH by Rusty Cranford and a small group of former leaders, who are no longer employed because of those actions. We understand this is an ongoing process and likely not the last action taken against former employees and vendors. We continue to cooperate with authorities as they follow the facts and the evidence, including information we are providing.
"The alleged actions of Mr. Raveendran do not reflect the values of PFH. While we cannot change the past misdeeds of others, we are committed to a new path forward by continuing to implement new and thorough processes and procedures. We are grateful to the more than 4,000 employees who continue to provide critical services to individuals throughout Arkansas and the four other states we serve."
PFH announced late Friday that it plans to appeal the DHS' decision to suspend Medicaid payments to PFH and exercise contract termination clauses in existing contracts.
Shortly before Raveendran was let go, three top executives at PFH were put on leave in November 2017 after they were implicated in kickback schemes by the plea agreement of Pennsylvania lobbyist D.A. Jones last year, then fired outright in January. A fourth top executive was put on leave this month after being implicated in Cranford's plea.