Serving nearby areas by Palm Beach and West Palm Beach, Florida


Compass Detox and WAR Treatment


            The South Florida Health Care Fraud Strike Force, consisting of agents from the FBI and Office of the Inspector General, arrested ten alleged perpetrators during an ongoing investigation into health care related crimes. The federal charges stem primarily from unlawful activities associated with the operation of two interconnected substance abuse treatment facilities in Broward County, Florida—Compass Detox and We Are Recovery/“WAR” Treatment Center.

Compass Detox and WAR Treatment

            According to its website,[1] Compass Detox is described as “one of the best drug & alcohol detox facilities in Florida,” boasting a luxurious and state-of-the-art facility in Pembroke Pines that can accommodate up to 40 patients at a time. Compass is licensed through Florida’s Department of Children and Families (DCF) and the Florida Department of Health, and further claims accreditation from medical services certification organizations, including The Joint Commission and LegitScript. Since March 24, 2017, Compass Detox has been licensed by the DCF to provide residential level 1 and detox services.

            Although Compass Detox did not offer services beyond medical detoxification, it shared common ownership with WAR Treatment, another facility in nearby Hallandale Beach, Florida. WAR Treatment was initially licensed by the DCF on February 7, 2019, to provide day/night treatment with community housing, intensive outpatient, and outpatient services. Notably, the association of these co-owned entities is not apparent from either organizations’ website or promotional materials. However, Compass Detox states that upon completion of its program, it works with clients to “evaluate . . . individual needs” and “recommend a program” for aftercare.


The Criminal Conduct

            On September 27, 2020, a lengthy criminal complaint[2] was filed in federal court by law enforcement detailing the findings of its investigation to that point. The allegations suggest that conduct violative of federal statutes had been occurring since April 1, 2017—one week after Compass Detox was initially licensed. The complaint alleges probable cause to believe that many of the insurance claims were false and fraudulent, including medical and clinical services provided by Compass and WAR directly, as well as third-party claims submitted by laboratory testing and chiropractic services for Compass and WAR patients. Among those charged are treatment center physicians, company owner/operators and personnel, as well as various third parties, including contracted “patient brokers.”

            While the criminal complaint encompasses the extent of the perpetrators’ alleged criminal conduct, one especially flagrant component of the scheme claims that “conspirators gave patients illegal drugs prior to admission and/or re-admission” in order to justify care at the highest and most expensive levels of care. The claims are corroborated, at least in part, by witness statements provided by former patients. According to some of the statements, patients regularly overdosed after being provided these drugs by Compass Detox personnel.

Law enforcement review of the claims submitted by the offending entities over a three year period revealed that approximately $91.2 million billed to insurers, and approximately $25.4 million paid.

A Not So Uncommon Story

In 2019, an article published by an investigative journalist sought to uncover predatory and exploitative practices by “recruiters” and “patient brokers” in the substance abuse treatment industry. The piece features the story of a young woman caught in the “Florida Shuffle” before eventually passing away. Compass Detox is cited by the author as one of the South Florida facilities entrusted with the custody and care of this young woman shortly before her death. Thus, as part of her investigation, the author obtained a statement from a Compass Detox spokesperson. The article describes the substance of the statement given by Compass:

Compass Detox spokesman said that paying clients for treatment and giving them drugs between rehab stints “is illegal and we don’t do that.” Compass obeys all relevant laws and regulations, he emphasized.




            The defendants are set for proceedings beginning in February 2021. A link to the Department of Justice press release can be found here.



At Romano Law Group, Rainer Boggiano is focused on representing plaintiffs in catastrophic injury matters, including wrongful death, negligence, medical malpractice, and products liability litigation.

Rainer earned his Juris Doctor from the University of Florida Levin College of Law in Gainesville, Florida and his Bachelor of Business Administration in Economics from Florida Atlantic University in Boca Raton, Florida.

While attending law school, Rainer served as a judicial extern at Florida’s Fourth District Court of Appeal and a legal intern for ADT Security Services at its corporate headquarters in Boca Raton. He graduated with multiple Dean’s List honors and was a Pro Bono Award recipient in recognition for completing 150+ hours of community service. Currently, he is assisting with the Pro Bono work on behalf of the Florida Association of Recovery Residences.

Rainer is active in several community organizations, having served as a volunteer for the 15th Judicial Circuit’s Guardian ad Litem Program, a tutor at the Mandel Public Library’s homework center, and a mentor for several local non-profit organizations.



Susan Ramsey is both an attorney and an RN. Ms. Ramsey’s professional experience began as a Registered Nurse in the Intensive Care Unit at Yale New Haven Hospital. While pursuing her Bachelor’s Degree, she was a counselor with the New Haven Rape Crisis Program. During her time with the Program, Ms. Ramsey counseled sexual assault survivors and performed seminars for local police departments, universities, and high schools. During her time working as a registered nurse, Ms. Ramsey decided to attend law school. Ms. Ramsey graduated from CUNY Law School, and has practiced law in several different State and Federal Courts.  She is a Florida Heath Care Risk Manager and a member of the Palm Beach County Sober Home Task Force.  Susan is Pro Bono Counsel for the Florida Association of Recovery Residences.

Ms. Ramsey actively litigates cases involving catastrophic injuries and wrongful death on behalf of survivors, cases include injuries suffered by victims of professional product liability and medical negligence.