I think he meant literally criminal.
The hospital double billed for over $100k worth of services on the original invoice.
At a certain point a pattern of issuing inaccurate invoices crosses the line into negligence.
If a business just have a habit of blasting out invoices that bill for services never received, and they know that they keep doing this, and only correct it when the customer points it out, at a certain point it turns into a crime.