On November 15, 2015, OIG excluded Todd Roberts and Roberts Physical and Aquatic Therapy, LLC a/k/a Roberts Physical Therapy and Wellness Center, LLC (collectively, Roberts), for a period of six years based on a material breach of its Corporate Integrity Agreement (CIA). During the first reporting period of its CIA, Roberts’ Independent Review Organization (IRO) identified an overpayment of $32,295, which Roberts has not paid. Roberts also failed to timely submit its Implementation Report, First Annual Report, and Second Annual Report. On June 16, 2014, OIG issued a letter demanding stipulated penalties in the amount of $24,000. OIG issued a notice of material breach and intent to exclude on September 1, 2015 for repeated and flagrant violations of the CIA and Roberts’ failure to respond to OIG’s demand letter. On October 15, 2015, OIG sent Roberts an exclusion letter. Under the terms of the CIA, Roberts had 25 days to request a hearing with an Administrative Law Judge. Roberts did not request a hearing, and the exclusion went into effect on November 15, 2015. Senior Counsels Lee Penninger, Tamara Forys, and Lauren Marziani represented OIG.