A 'Voluntary' Organization Quietly Became Medicaid's Third-Largest Billing Entity at $5.6 Billion
Tempus Unlimited Inc., classified as a voluntary or charitable organization in Massachusetts, billed $5.57 billion across 63.5 million claims.
Automated analysis by MedicaidWatch · February 2026
The 3rd largest Medicaid billing entity in America is classified as a 'Voluntary or Charitable' organization. Tempus Unlimited: $5.57 BILLION. 98% from one code. The data is now public.
Tempus Unlimited, Inc., headquartered in Stoughton, Massachusetts, has billed $5.57 billion to Medicaid since January 2018. That makes it the third-highest paid entity in the entire national Medicaid dataset — behind only state agencies and major managed care organizations. It's classified in the NPPES registry as a 'Voluntary or Charitable' organization.
The billing profile tells a focused story: 98.05% of Tempus's $5.57 billion — or $5.46 billion — comes from code T1019, personal care services. The organization has processed 63.5 million claims for 3.35 million beneficiary-records over 84 months of continuous billing. Like FreedomCare in New York, Tempus operates as a fiscal intermediary, processing caregiver payments under Massachusetts' consumer-directed care programs.
The growth trajectory is notable. From January 2018 monthly billing of approximately $34 million for T1019 alone, Tempus's monthly revenue has grown steadily. With 3.35 million beneficiary-records (which includes repeat enrollees across months), the organization touches a significant share of Massachusetts' Medicaid population through personal care services.
Tempus also operates under a second NPI (1275752065) with the same authorized official, CEO Larry Spencer, and the same address at 600 Technology Center Drive in Stoughton. Combined billing across both NPIs could exceed $6 billion, making the full entity potentially the second-largest billing operation in the dataset. The use of multiple NPIs for what appears to be a single organization raises questions about billing structure and oversight.
The 'Voluntary or Charitable' classification alongside $5.57 billion in Medicaid receipts creates a striking contrast. While the classification reflects the organization's legal structure, the scale of taxpayer funds flowing through this entity suggests that scrutiny proportional to its size is warranted. Massachusetts auditors should examine whether the oversight infrastructure matches the $800+ million per year in claims processing.
Billing Timeline
Monthly Medicaid payments, 2018-01 – 2024-12
Revenue by Billing Code
Percentage of total revenue from each HCPCS procedure code
Compared to Peers
Cost per claim and intensity vs. national median for each billing code
Key Findings
- $5.57 billion in Medicaid payments — third-highest billing entity nationally
- 98.05% of revenue from a single code (T1019) — 63.5 million claims
- Classified as 'Voluntary or Charitable' while processing $800M+ per year
- Operates under two NPIs (1376609297 and 1275752065) with same CEO and address — combined billing likely exceeds $6 billion
- 3.35 million beneficiary-records across 84 continuous months of billing
Why This Might Not Be Fraud
Tempus Unlimited is a well-established fiscal intermediary in Massachusetts, operating since at least 2006. As a fiscal intermediary for consumer-directed care, high single-code concentration is expected. The 'Voluntary or Charitable' designation reflects its nonprofit status, not necessarily its scale. Massachusetts has specific programs requiring fiscal intermediaries for personal care services.
Questions for Investigators
- ? Why does Tempus Unlimited operate under two separate NPIs (1376609297 and 1275752065) with the same CEO and address?
- ? What audit and oversight mechanisms are proportional to $800M+ per year in Medicaid claims processing?
- ? How does Massachusetts verify that personal care services billed through Tempus are actually being delivered to 3.35 million beneficiary-records?