Is There Really an "Funny Looking Name" Phenomenon in Anomalous Medicare Lab Billing??

 We have studied the odd names of labs that billed 81419 (epilepsy gene panel) to Medicare in 2023. There was a lot of known Medicare fraud in 2020 caused by labs that billed code 81408 (full sequence, rare gene, $2000) to Medicare. I include the names of labs that billed 81419 in 2023, and labs that billed 81408 in 2020. 

Now, I am also including labs that billed a common and mundane code to CMS - 81443, Thyroid Stiumulating Hormone $16. Using some of the insights you saw above, but also new insights you may develop, discuss anomalous names of 81419 labs, of 81408 labs, and, finally, put these in a setting of relatively unselected labs billing 81443. (Of course, a few of the labs billing 81443 could be fraudulent, not impossible.)

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Here’s a structured comparison of the naming patterns across three groups of Medicare labs — the ones billing 81419 (epilepsy panel), 81408 (rare gene full seq), and 81443 (routine TSH).

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1. 81419 Epilepsy Gene Panel (2023)

• Highly “engineered” names: 58% include “LLC,” suggesting rapid shell formation for billing.

• Marketing-style branding: Frequent use of “Elite,” “Express,” and “Global,” which signal prestige rather than location or science.

• Genomics jargon: “Gene,” “Bio,” “Diagnostics” are common — giving a veneer of modernity.

• Lookalike risk: Names like Elite Bio Reference Laboratory echo national players like BioReference, which might confuse payers.  See also:   GeneTx, which someone might confuse for "GeneDx," a very large publicly held lab.

• Pattern: Concentrated in Novitas/FCSO states, similar to prior 81408 fraud.

This cluster feels like it was designed for Medicare billing rather than clinical branding — often placeless, ownerless, and likely ephemeral.

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2. 81408 Rare Gene Full-Seq (2020)

• Even higher LLC usage: 74% of labs are LLCs — even more than 81419, reinforcing the “set up & dissolve” pattern.

• Fewer prestige words: Most names are plain but corporate-sounding (Your Choice Laboratory LLC, Oakwood Lab Services LLC), projecting neutrality.

• Somewhat less genomics jargon: Only 13% mention “Gene,” vs. nearly 20% of 81419 labs.

• Key observation: 81408 labs were numerous (74 unique labs) and widely dispersed, but many were later linked to OIG findings of massive improper payments. [See OIG Report about the "billion dollar code."]

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3. 81443 TSH (Routine, $16 Test)

• Much more mainstream profile: 973 unique labs, including Quest Diagnostics, LabCorp, regional hospitals, and university systems.

• Lower LLC rate (30% compared to 74% for 81408), higher Inc. rate (41%) — reflecting large established corporations.

• Rare “prestige words”: Almost no “Elite” or “Express” — only 0.2% use them.

• Clear locality/ownership signals: Many names include city, region, or hospital name, suggesting real brick-and-mortar providers.

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4. Putting It Together

Feature	81408 (2020)	81419 (2023)	81443 (Routine)
LLC usage	74% – very high	58% – still high	30% – lower
Prestige words	Low	High (“Elite,” “Express,” “Global”)	Nearly absent
Genomics jargon	Moderate (13%)	High (19%)	Rare (2%)
Locality in name	Rare	Rare	Common
Association with fraud	Known OIG target	Rapid rise, suspicious pattern	Mostly mainstream

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Interpretation

• 81419 is the “new 81408.” The naming style shows slightly more polish, more “science branding,” and an obvious intent to look legitimate to payers.

• 81408 was rawer: mostly cookie-cutter LLCs, still enough to fool Medicare into paying $888M before OIG stepped in.

• 81443 shows what normal looks like: established labs with geographic anchors, brand equity, and no need to sound like a biotech marketing deck.

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