United States v. Elmi

A federal grand jury in the District of Minnesota returned an eleven-count indictment on October 22, 2026, charging Feisal Mohamed Elmi with health care fraud and aiding and abetting under 18 U.S.C. sections 1347 and 2. Elmi is the beneficial owner of Aspen Associates LLC, a Minnesota limited liability company he formed in March 2014 and enrolled as an EIDBI provider agency with the Minnesota Department of Human Services on October 10, 2020. On that same date, Elmi certified to DHS that he would comply with all applicable federal and state statutes and assumed full responsibility for the accuracy of claims submitted. The EIDBI program is a federally funded Minnesota Medicaid benefit that covers applied behavior analysis therapy, DIR/Floortime, and related services for individuals under age 21 diagnosed with autism spectrum disorder or related conditions. Covered services must be medically necessary, authorized by a Qualified Supervising Professional, delivered pursuant to an individualized treatment plan, and documented in health service records that include start and stop times, provider signatures, and current CMDEs and ITPs. The indictment alleges that from approximately March 2021 through January 2026, Elmi and others submitted and caused the submission of false and fraudulent claims to Minnesota Medicaid for EIDBI services that were not actually provided, were not authorized by a QSP, and were billed as though rendered by providers and to beneficiaries located in the United States when, in fact, the identified providers or beneficiaries were outside the United States at the time of the purported service. Counts 1 through 11 each identify a specific false claim submitted through Aspen between September 23, 2022 and March 27, 2025, covering EIDBI service categories including family or caregiver training, observation and direction, individual intervention adaptive behavior treatment, comprehensive multi-disciplinary evaluation, and individual treatment plan development and monitoring. Each enumerated claim was billed to Medicaid for $800. In total, the indictment alleges that Aspen submitted approximately $7.487 million in false and fraudulent claims, of which Medicaid reimbursed approximately $2.8 million. The forfeiture allegations seek a money judgment equal to the gross proceeds traceable to the scheme under 18 U.S.C. section 982(a)(7), with substitute-asset provisions under 21 U.S.C. section 853(p) as incorporated by 18 U.S.C. section 982(b) and 28 U.S.C. section 2461(c).