HHS-OIG Investigation: University of Michigan MiChart Allegations and NIH Grant R01NS082304 — What Happened to the Medical-Billing Allegations?

On May 1, 2025, HHS-OIG partially released 12 pages of records concerning Case No. 5-17-0-0192-4, following an inquiry by the Office of U.S. Senator Ben Cardin about Dr. Bradley Foerster’s outstanding FOIA request and administrative appeal. HHS-OIG also reported locating a DVD originating with the Ann Arbor Police Department.

In the October 4, 2024 request for Senator Cardin’s assistance, Dr. Foerster stated that the case apparently stemmed from a complaint filed under Dr. Petrou’s name without her knowledge or consent, that Dr. Petrou had disassociated herself from that complaint, and that neither his February 2024 FOIA request nor his subsequent appeal had received a response.

The released memoranda gave Dr. Foerster a clearer account of what HHS-OIG had investigated—but left important questions unanswered.

The October 6, 2017 Opening Investigative Memorandum identifies both MiChart up-coding allegations within the University of Michigan Department of Radiology and alleged grant fraud involving NIH Grant R01NS082304. It states that HHS-OIG’s Office of Investigations was the sole investigating agency at that time.

By September 10, 2018, the interim memorandum describes the case in terms of alleged fraud involving the NIH-funded study. It reports that witness interviews had been conducted and records obtained from witnesses and directly from the University of Michigan. It does not discuss the MiChart up-coding allegations. The August 21, 2019 Closing Investigative Memorandum likewise describes the case as involving alleged grant fraud.

The released records do not explain what happened to the medical-billing and MiChart allegations identified when the case opened, or provide findings resolving those allegations.

That omission matters in light of a separate HHS-OIG FOIA response. HHS-OIG reported finding no responsive records of investigations or reports concerning medical-billing/MiChart practices at University of Michigan Radiology for January 1, 2017, through January 1, 2020—a period that includes the opening memorandum.

HHS-OIG’s opening memorandum documents MiChart up-coding allegations within University of Michigan Radiology, yet the separate FOIA response reports no records of investigations or reports concerning those practices during the same period.

The production also raises a question about the interview records. In 2021, Assistant U.S. Attorney Dedra Curteman told Dr. Foerster that “interview reports were not created by HHS.” In 2025, HHS-OIG released documents expressly titled Reports of Interview under the same case number. The records reviewed here do not explain that apparent discrepancy.

Those reports are heavily redacted. Interviewee identities, dates, and much of the information provided are withheld, leaving Dr. Foerster unable to reconstruct substantial parts of the investigative activity.

The later disposition of the grant investigation, including the U.S. Attorney’s declination of criminal prosecution, is documented separately. The 2025 production left unresolved the handling of the original MiChart allegations, the separate “no responsive records” response, and the interview reports Dr. Foerster had previously been told were not created.

Congressional Inquiry and FOIA Appeal — Office of Senator Ben Cardin


May 1, 2025 — HHS-OIG FOIA Determination


October 6, 2017 — Opening Investigative Memorandum
September 10, 2018 — Interim Investigative Memorandum
HHS-OIG Reports of Interview

August 21, 2019 — Closing Investigative Memorandum

Twelve pages of records were identified and partially released.

HHS-OIG Case 5-17-0-0192-4 Documentary Chronology
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Brad Foerster, MD PhD

Brad Foerster is a FOIA advocate documenting requests, transparency disputes, and accountability investigations involving public agencies, universities, police oversight, and Russia-Gate related inquiries. His work compiles original documents, timelines, and analysis of public records and institutional responses. Brad is also a board-certified radiologist, author of Town & Gown, and has published over 40 peer-reviewed articles. Brad lives in Potomac, Maryland with his family and is a member of the Montgomery County Medical Society and the Takoma Park U.S. & World History Book Club.