creation of fabricated referral paperwork.” We disagree. Fabricating paperwork to deceive the Government into paying money can support the sophisticated means enhancement. See United States v. Pierce, 643 Fed.Appx. 500, 503 (6th Cir. 2016); see also United States v. Crosgrove, 637 F.3d 646, 667 (6th Cir. 2011). Hut the district court did not rest its decision solely on Griffith’s creation of fabricated referral paperwork, The district court determined that Griffith used sophisticated means by recruiting Medicare beneficiaries, creating fraudulent referral paperwork, and posing as a licensed physician to prescribe narcotics and home healthcare services to patients. In light of this evidence, the district court’s decision was hot clearly erroneous. See Mahmud, 541 Fed. Appx. at 636 (<HOLDING>). C. Griffith’s third and final challenge to
holding that district court did not err in finding that similar scheme involved sophisticated means holding that the district court did not err in determining that inadvertent disclosure did not result in waiver holding that district court did not clearly err in giving twolevel enhancement for similar conduct holding that based upon means similar to or supported by holding that trial court did not err