Billing code H2015 — "comprehensive community support services, 15 min" — is used for wrap-around support services for people with mental illness and developmental disabilities. Nationally, it accounts for $16.5 billion in Medicaid spending across 3,908 providers. It's a legitimate and necessary service category.

But in Michigan, several providers billing H2015 show claims-per-beneficiary ratios that are extreme outliers — far above what the same code produces in other states.

The Outliers

Provider	Total Paid	Claims	Beneficiaries	Claims/Bene	Codes Billed
Starr's Watchful Eye	$3.5M	324,836	1,381	235	2
JARC	$9.2M	310,532	2,641	118	2
Community Administrative Services	$3.2M	52,245	591	88	2
Quality Choice Home Healthcare	$6.6M	90,364	1,233	73	2
Integrated Living, Inc.	$2.3M	26,088	378	69	2
D & M Consultants, Inc	$4.2M	43,932	648	68	1
New Outlook, Inc.	$17.6M	206,108	3,187	65	3
RGRPS, Inc.	$24.0M	312,564	5,369	58	5

What Does 235 Claims Per Beneficiary Mean?

Starr's Watchful Eye filed 324,836 claims for 1,381 beneficiaries over the dataset period (2018–2024). That's 235 claims per person — roughly one claim per beneficiary every 1.5 days, sustained over seven years. Since H2015 is billed in 15-minute increments, this could represent regular daily check-ins. But the ratio is far above typical providers billing the same code.

For context: if you assume 250 working days per year across 7 years, that's 1,750 possible billing days. At 235 claims per beneficiary, these providers are billing H2015 roughly every 7.4 days per person. In 15-minute increments, that might be reasonable for intensive community support. But the fact that it's so concentrated among Michigan providers — and specifically these providers — is the anomaly.

The Pattern

Several things stand out about this cluster:

• Almost all bill exactly 2 codes. Six of the eight providers bill exactly 2 HCPCS codes total — their entire Medicaid operation runs through two billing codes. D & M Consultants bills just one.
• All are in Michigan. The top 8 claims-per-beneficiary providers in the entire dataset (among those with 50+ beneficiaries and $500K+ spending) are all in Michigan.
• The dollar amounts are modest. Unlike the Brooklyn personal care agencies billing billions, these providers range from $2.3M to $24M. This isn't mega-scale fraud territory — it's a question of intensity per person.
• H2015 is the common thread. Every single one of these providers has H2015 as their primary billing code.

Why Michigan?

Michigan's Medicaid program structures its community mental health and developmental disability services through a system of Community Mental Health Services Programs (CMHSPs) and Prepaid Inpatient Health Plans. Providers in this system bill intensive support services — including H2015 — at high frequency because the program model is built around continuous community-based care rather than episodic treatment.

So the high claims-per-beneficiary ratios may reflect Michigan's program design rather than abuse. A provider delivering daily 15-minute check-ins to severely mentally ill or developmentally disabled clients in a community setting would generate exactly this billing pattern.

But "may" is doing heavy lifting in that sentence. The question is whether these ratios are normal for Michigan's program model, or whether specific providers are inflating claim counts beyond what services were actually delivered. That's an audit question, not a data question — and these providers would be natural candidates for one.

Other High-Ratio States

Michigan isn't the only state with high claims-per-beneficiary outliers. Louisiana has several (G B Cooley Hospital Services at 72, Crossroads LA at 69, Helping Hands of New Orleans at 66), and Missouri's At Home Care St. Louis CDS hits 102. But none approach Michigan's concentration of extreme ratios in a single billing code.

Explore all Michigan Medicaid providers at medicaidspending.org/state/MI, or browse the national H2015 data at medicaidspending.org/code/H2015.