One Company Billed $3 Billion for a Single Home Care Service Code
FreedomCare LLC collected 99.3% of its $3.03 billion in Medicaid payments from a single procedure code over 7 years.
Automated analysis by MedicaidWatch · February 2026
$3 BILLION from Medicaid. One company. One billing code. 99.3% concentration. FreedomCare LLC in New York is one of the largest single-code entities in the system. The data is now public.
FreedomCare LLC, based in New Hyde Park, New York, has collected $3.03 billion from Medicaid since 2018. Of that, $3.004 billion — 99.3% — came from a single procedure code: T1019, personal care services. That makes FreedomCare one of the largest single-code billing entities in the entire Medicaid system.
The scale is staggering. Over seven years, FreedomCare billed 21.9 million claims for 1.16 million unique beneficiaries at an average of $137.68 per claim. To put the $3 billion figure in perspective, it exceeds the entire annual Medicaid budget of at least 10 U.S. states. The company's monthly billing grew from $5.7 million in January 2018 to over $60 million per month by late 2024 — a ten-fold increase.
FreedomCare operates in the Consumer Directed Personal Assistance Program (CDPAP), a New York Medicaid program that allows patients to hire their own caregivers, including family members. The program has faced significant scrutiny: in 2023, New York Governor Kathy Hochul proposed sweeping reforms after audits found billions in questionable spending. FreedomCare is the largest fiscal intermediary in the program, serving as the billing entity that processes caregiver payments.
The concentration raises questions about market structure rather than necessarily fraud. When a single entity controls $3 billion in billing for one service type, the question becomes: Is there adequate oversight of service delivery? Are the 1.16 million beneficiaries receiving verified care? What happens to quality when one company becomes the billing conduit for this scale of taxpayer funds? The recent addition of new codes (T1022, S5125, 99199) starting in late 2024 suggests the company may be diversifying — or adapting to regulatory changes.
An investigator should examine whether FreedomCare's growth correlates with the documented problems in New York's CDPAP program and whether service verification mechanisms are adequate for a $3 billion annual operation.
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
- $3.03 billion in total Medicaid payments — 99.3% from a single code (T1019)
- 1.16 million unique beneficiaries served across 21.9 million claims over 7 years
- Monthly billing grew 10x from $5.7M (Jan 2018) to $60M+ (late 2024)
- One of the largest single entities in the entire U.S. Medicaid system
- New billing codes appeared in late 2024, suggesting business model evolution
Why This Might Not Be Fraud
FreedomCare is a fiscal intermediary in New York's CDPAP program, which by design concentrates billing through intermediary entities. High code concentration is expected for this business model. The company is publicly known and state-regulated. However, the CDPAP program itself has been subject to multiple state audits identifying systemic overbilling.
Questions for Investigators
- ? What service verification mechanisms exist for 1.16 million beneficiaries billing through a single fiscal intermediary?
- ? How does FreedomCare's growth trajectory correlate with documented CDPAP program integrity findings?
- ? What explains the introduction of new billing codes (T1022, S5125, 99199) in late 2024 — diversification or regulatory response?