Medea Woods v. State of Indiana, 2012 Ind. App. LEXIS 638

Woods, a licensed clinical psychologist, billed Medicaid from 2002–2007 and kept records to support claims; she faced a five-year limitations period for misconduct prior to 2006.
The Medicaid program required proper records, allowed audits, and required return of erroneous payments within 15 days.
Health Care Excel audited Woods in 2006 for disproportionately high billing, leading to pre-payment review.
Hedges of the Medicaid Fraud Control Unit investigated Woods; she was found to have fraudulently billed using patient RID numbers.
Woods was federally charged in 2009 with health-care fraud; state charges followed in 2011 alleging the same conduct from 2002–2007.
Woods moved to dismiss portions of the charges as time-barred; the trial court denied, and this interlocutory appeal followed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the information and probable-cause affidavit sufficiently allege concealment and timeliness.	Woods argues concealment not pled with sufficient detail within the statute.	State contends the information plus affidavit together place Woods on notice and within the period.	Yes; the combined documents sufficiently allege concealment within the limitations period.

Reeves v. State, 938 N.E.2d 10 (Ind. Ct. App. 2010) (hold that charging information alone may be insufficient; concealment must be pled)
Patterson v. State, 495 N.E.2d 714 (Ind. 1986) (probable-cause affidavit can supplement deficient charging information)
Kifer v. State, 740 N.E.2d 586 (Ind. Ct. App. 2000) (concerning tolling and concealment doctrine)
Willner v. State, 602 N.E.2d 507 (Ind. Ct. App. 1992) (statutory information requirements for charging)
State v. 966 N.E.2d 619, 966 N.E.2d 619 (Ind. Ct. App. 2012) (related discussion on concealment and limitations in this context)
Sloan v. State, 947 N.E.2d 917 (Ind. 2010) (acknowledges scope of concealment evidence in tolling)