Lackawanna Connect | February 14, 2025

Yesterday we published an analysis of the DOGE HHS Medicaid dataset focused on Lackawanna County. The standout finding was Bright Beginnings Therapeutic Services, a company registered to a small suite on North Main Street in Carbondale, billing $46.7 million in ABA therapy codes to Pennsylvania Medicaid over four years. That made them the 21st largest ABA biller in the country, despite listing 2 to 10 employees on LinkedIn.

Within 24 hours of publication, the original founder of Bright Beginnings contacted us. What she told us sent the story in a direction we didn't expect.

Quick Background: What's an NPI?

Before we go further, a brief explainer. An NPI -- a National Provider Identifier -- is a unique 10-digit number assigned to every healthcare provider in the United States. There are two types.

A Type 2 NPI belongs to an organization -- the company that sends the bill. Think of it as the plumbing company. Joe's Plumbing has a business license and sends you the invoice.

A Type 1 NPI belongs to an individual -- the actual person who provided the service. That's the plumber who showed up at your house and fixed your pipes.

In Medicaid billing, every claim is supposed to identify both: the billing provider (the company, Type 2) and the servicing provider (the individual, Type 1). The billing NPI tells you who got paid. The servicing NPI tells you who actually did the work. When that second field is blank, there's no record of who provided the care -- or whether it was provided at all.

That distinction is central to everything that follows.

What the Founder Told Us

The founder, who started Bright Beginnings in 2017, told us she sold the company to a private equity firm called Investment 360, which rebranded as Attain ABA. She provided inconsistent dates for the sale -- initially stating 2018, later clarifying it as September 2019. She said the company is now based in Lakewood, New Jersey, with services provided across multiple states. And she said individual provider NPIs are not required for behavioral health billing in Pennsylvania -- that employees are hired under the group NPI.

We presented our findings to her in writing and asked her to identify any specific factual errors. She stated that "most of what you are saying" was incorrect, but declined to specify what when asked directly. She was given multiple opportunities to correct the record in writing and did not do so.

So we investigated every claim she made. The result didn't explain the anomalies away. It made them worse.

Who Is Attain ABA?

Attain ABA is a national ABA therapy company controlled by Eliezer Friedman, listed as Managing Member on all of the company's federal NPI registrations. The company is headquartered at 850 Towbin Avenue in Lakewood, New Jersey. Sam Wallach has served as President since June 2021. Before that, Wallach was Vice President of Business Development at Investment 360 -- the same firm the founder identified as the buyer of Bright Beginnings.

Attain ABA operates in at least 14 states and Washington, D.C. It has 11 separate organizational NPIs registered with the federal government, each named for a different region: Attain ABA NE, Attain ABA SE, Attain ABA West, Attain ABA FL, Attain ABA GA, Attain ABA MA, Attain ABA CT, Attain ABA NC, Attain ABA Indiana, Attain ABA IL, and Attain ABA MW.

In March 2022, Attain ABA acquired Kadiant, a competing ABA company that had been launched in 2019 with ** $300 million in equity capital from TPG Capital**, one of the largest private equity firms in the world. Kadiant had operations in California, Colorado, Georgia, Ohio, Oregon, and Washington state, and held **8 additional organizational NPIs**. How a company founded around 2019 in Lakewood, NJ acquired a$ 300 million-backed competitor has not been publicly explained.

Between Attain ABA, Kadiant, and Bright Beginnings, the enterprise holds at least 21 organizational NPIs across the country. Employee estimates range from 500 to over 1,000. One data provider estimates revenue at $18.1 million, though this figure appears low given the billing volumes we found.

Where the Money Actually Flows

This is where it gets interesting.

We searched the entire DOGE HHS Medicaid dataset -- all 227 million rows, $1 trillion in spending -- for every one of those 21 NPIs. Here's what came back:

Entity	Total Billed	% of Enterprise Total
Bright Beginnings (Carbondale, PA)	$46,755,305	86.2%
Attain ABA NE LLC (Lakewood, NJ)	$5,937,741	10.9%
Kadiant LLC (Oakland, CA)	$1,171,155	2.2%
Attain ABA West LLC (Denver, CO)	$215,526	0.4%
Bright Beginnings - Early Intervention	$177,541	0.3%
16 other NPIs	$0	0%

**The combined enterprise total is $54.3 million.** Of that,$ 46.7 million -- 86 percent -- flows through the single Bright Beginnings NPI registered to Carbondale.

Sixteen of the twenty-one NPIs show zero Medicaid billing in the dataset. For a company operating in 18 states with hundreds of employees, the absence is striking. But it's the concentration that demands explanation: why is a national company with dedicated regional NPIs for the Northeast, Southeast, Midwest, and a dozen individual states routing the overwhelming majority of its Medicaid revenue through one acquired provider in Carbondale, Pennsylvania?

The Smoking Gun: Who Provided the Therapy?

Remember the billing vs servicing NPI distinction from above. In our original analysis, we flagged that 75% of Bright Beginnings' claims -- $34.9 million worth -- have no servicing provider NPI listed. That's the field that identifies the individual person -- the plumber, not the plumbing company -- who actually sat with the patient and delivered the therapy. When it's blank, there is no record in the data of who performed the service.

We noted that the national average for blank servicing provider fields in these billing codes is about 12%. Bright Beginnings was at 75%.

The founder told us this was normal -- that Pennsylvania's behavioral health billing system doesn't require individual NPIs.

So we checked two things.

First, we checked the regulations. Pennsylvania's Department of Human Services states explicitly: "When invoicing for payment, the MA number of the individual practitioner who performs the service must be identified as the rendering provider." Every major Pennsylvania Medicaid managed care organization -- Magellan, Aetna Better Health, PA Health & Wellness, Community Behavioral Health of Philadelphia -- requires rendering provider NPIs on claims. Pennsylvania's PROMISe claims processing system has specific error codes for missing or invalid rendering NPIs. The founder's claim is not supported by the regulatory framework.

Second, we checked Attain ABA's own billing.

When Attain ABA bills Medicaid under its own name -- through the Attain ABA NE and Attain ABA West NPIs -- the servicing provider field is populated on 100% of claims. Zero blanks. Every single claim identifies the individual who provided the service.

When the same company bills through the Bright Beginnings NPI, 75% of claims by dollar volume have no servicing provider identified.

Same company. Same type of services. Same billing codes. Same parent organization. Different behavior depending on which NPI they use. They clearly have the infrastructure and the knowledge to identify rendering providers. They do it everywhere except on the NPI that carries 86% of their billing volume.

What This Pattern Looks Like

There is a specific reason regulators require the servicing provider to be identified on claims. It's the primary mechanism for verifying that:

Services were actually delivered
The person who delivered them was qualified
No single provider is billing an impossible number of hours
The services are not fictitious

When the servicing provider field is blank on $34.9 million in claims, none of those checks can be performed against the data. There is no way to determine from the public record whether 120 qualified behavior technicians delivered 186,000 hours of one-on-one therapy in 2024, or whether a smaller number of people billed for sessions that didn't happen, or something in between.

The Minnesota ABA fraud cases that prompted the DOGE HHS data release involved exactly this kind of opacity. Companies hired unqualified individuals -- sometimes teenagers, sometimes family members of the patients -- listed them as behavior technicians, and billed Medicaid for therapy that was never delivered or was delivered by people with no training. The claims looked plausible in aggregate. It was only when investigators tried to match individual claims to individual providers that the fraud became visible.

A 75% blank rate on the servicing provider field makes that kind of matching impossible.

The Geography Question

Attain ABA is headquartered in Lakewood, New Jersey. It holds regional NPIs registered to addresses in New Jersey, Colorado, California, and other states where it operates. Yet 86% of its Medicaid billing flows through an NPI registered to a small suite in Carbondale, Pennsylvania — a town of about 8,600 people.

The company's own regional NPIs exist specifically to bill in the areas where services are provided. The question is why they aren't being used for that purpose, and why a single acquired NPI in a small northeastern Pennsylvania town carries nearly all of the enterprise's Medicaid volume instead.

What Parents Are Saying

While investigating Attain ABA's operations, we found consumer reviews on ABA Navigator, a parent review site for ABA therapy providers.

One parent reported that a therapist "fabricated in her notes daily" and that "the therapist was forging our signature in the system, and lying about the time she started the sessions."

Another parent reported a therapist who was "laying down sleeping" during a child's session.

Multiple parents reported extreme therapist turnover -- more than 10 different therapists assigned to their child within a single year.

These are individual complaints and may not be representative of the company's overall operations. But they describe exactly the kinds of service delivery problems -- fabricated documentation, unengaged staff, high turnover of potentially unqualified workers -- that characterize the ABA fraud cases prosecuted in other states.

The Acquisition Trail

The corporate history raises its own questions.

Bright Beginnings was founded by a local clinician in Carbondale in 2017. The NPI was registered in April 2018. As of August 2018, the founder was still filing regulatory comments as President. The founder told us the company was sold to Investment 360 in September 2019, though the NPI registration was never updated to reflect the change in ownership. The founder remains listed as the Authorized Official on the NPI today -- six years and $46.7 million in billing later.

Attain ABA's own entities began registering NPIs in August and September 2019, consistent with the timeline the founder provided. No public record of the Bright Beginnings acquisition -- no press release, no news article, no publicly available corporate filing -- has been found.

In March 2022, Attain ABA acquired Kadiant, which had $300 million in TPG Capital equity behind it and operations in six states. The structure of that deal -- how a company barely three years old acquired a$ 300 million-backed competitor -- is not publicly documented.

After the acquisition, according to employee reviews, Kadiant's CEO was fired and employee benefits were significantly reduced, including paid mileage, client cancellation coverage, PTO, paid holidays, and tuition assistance.

What We're Not Saying

We are not alleging that Attain ABA, Bright Beginnings, Eliezer Friedman, Sam Wallach, or any individual has committed fraud. We do not have access to internal records, therapy logs, staffing documentation, or patient files. There may be legitimate business reasons for the billing patterns we observed.

What we are reporting is:

A national ABA company is routing 86% of its Medicaid billing through a single acquired NPI in Carbondale, PA, while its own regional NPIs carry minimal volume and 16 of its 21 NPIs show zero billing.
The same company identifies individual rendering providers on 100% of claims filed under its own name, but leaves the field blank on 75% of claims filed through the Bright Beginnings NPI.
The regulatory framework in Pennsylvania requires rendering provider identification on claims. The company's own billing practices on other NPIs demonstrate they have the capability to comply.
The billing volume through this single NPI -- $46.7 million, ranking 21st nationally -- requires a clinical workforce of 150 or more, operating through a registration that has never been updated from its original 2018 filing.
Consumer complaints describe documentation fabrication, signature forging, and disengaged staff at the company's operations.

These are public facts derived from federal data, federal provider registries, state regulatory guidance, and publicly available consumer reviews. The founder of Bright Beginnings, who contacted us after our initial publication, was given the opportunity to respond to these findings in writing. We present them so that the people whose tax dollars fund Pennsylvania Medicaid can evaluate them for themselves.

What You Can Do

If you have information about any of the entities discussed in this analysis:

Pennsylvania Attorney General's Medicaid Fraud Control Section: 717-787-4530
HHS Office of Inspector General Fraud Hotline: 1-800-HHS-TIPS (1-800-447-8477)
FinCEN BSA E-Filing System: For reporting suspected financial crimes related to Medicaid fraud

The DOGE HHS dataset is publicly available.

This is Part 2 of our analysis of the DOGE HHS Medicaid Provider Spending dataset. Part 1 is available here. All analysis was performed on publicly available federal records. Provider and corporate information was cross-referenced with the NPPES National Provider Registry, the Philadelphia Community Behavioral Health provider directory, Pennsylvania DHS regulatory guidance, corporate registration databases, and publicly available consumer review platforms.