Not Sure If This Is Medicaid Fraud Or Illegal In General?[tn]

Throw away account since my profession (genetic counseling) is small and I’m generally active in that subreddit. I’m a genetic counselor in TN and regularly place orders for genetic testing, which I am licensed to do. However, genetic counselors are not recognized as official medical providers by the federal government, so Medicare/medicaid does not reimburse for our services. Essentially, we are recognized as ordering providers by licensing states but not by the federal government. Also, for insurance plans that require genetic testing to be ordered through a qualified provider, testing will not be reimbursed. So.. we’ve always been told by our boss to list the referring provider (always MDs or NPs) as the ordering provider, even though we are licensed to place orders ourselves. He said this is for “liability reasons,” since he wants another provider to be responsible for follow-up care and further orders (this kinda makes sense since we don’t order MRIs or anything other than generic testing). While I work with other providers in other departments to coordinate patient care, I don’t work under them, if that makes sense (there’s no MD/NP in my department nor are they with us during an appointment). It has always seemed strange to me since we will put external providers as ordering providers, even though they don’t work with us at all (external providers probably have the impression that they are ordering a referral but may not realize that are now responsible for ordering a test).
My question is, should we be doing this? Is this some weird way to increase Medicare/medicaid reimbursement for testing? My boss is unethical in several ways, I’m genuinely unlearning things he has taught us and trying to navigate what our department should/shouldn’t be doing. This is also my first job out of grad school. I asked my colleagues at other institutions and they say they always set up a patient with an internal MD prior to ordering testing, or they work with an MD directly.
Thanks in advance your insight!
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