MEDICARE ADVANTAGE (Part C) EDUCATION AND TRAINING

Size: px
Start display at page:

Download "MEDICARE ADVANTAGE (Part C) EDUCATION AND TRAINING"

Transcription

1 MEDICARE ADVANTAGE (Part C) PRESCRIPTION DRUG (Part D) FRAUD, WASTE, and ABUSE EDUCATION AND TRAINING 1

2 INTRODUCTION CMS has mandated that Medicare Advantage Organizations (MAOs) and Prescription Drug Plan (PDP) Sponsors provide fraud, waste and abuse training for all entities they partner with to provide benefits or services, not just to direct employees within their organizations. Training must be completed annually. To meet this requirement, Indiana University Health Plans (IU Health Plans) is providing this training module. You can also access it at This training will cover the following topics: Laws and regulations related to MA and Part D fraud, waste and abuse (i.e. False Claims Act, Anti Kickback statute, HIPAA, etc.) Obligation to create policies and procedures to address fraud, waste and abuse Recognizing, reporting, and preventing suspected fraud, waste and abuse Protections from those who report suspectedfraud, waste andabuseabuse 2

3 OBJECTIVES Describe the CMS Fraud, Waste and Abuse training requirements for first tier, downstreamandrelated and related entities Prevent fraud, waste, and abuse in the administration of federal and state health programs Provide information for providers and employees to detect and fight fraud, waste, and abuse Provide information on protection for employees to encourage reporting of issues 3

4 DEFINITIONS Part C Medicare Advantage Plans (MA) provide all of a person s Part A and B coverage offered by private entities and may include prescription drug coverage (Part D) Part D Plans voluntary prescription p drug coverage available to everyone with Medicare person can buy a stand alone plan, or belong to an MA plan that offers this coverage (MA PD) 4

5 DEFINITIONS cont d Medicare Advantage Organization Apublic or private entity organized and licensed by astateasariskbearing entity (with the exception of provider sponsored organizations receiving waivers) that is certified by CMS as meeting the MA contract requirements. Part D Sponsors A PDP Sponsor, MA organization offering a MA PD plan, a PACE* plan including qualified prescription drug coverage, and a Cost Plan offering qualified prescription drug coverage. This includes employer and union sponsored plans. *PACE is the Program of All Inclusive Care for the Elderly 5

6 DEFINING Fraud Waste Abuse 6

7 Defining Fraud, Waste, and Abuse Health Care Fraud Intentionally, or knowingly and willfully attempting to execute a scheme to falsely obtain money from any health care benefit program. Specific to Medicare this would include billing Medicare for services that were never provided or received. 7

8 Defining Fraud, Waste, and Abuse Waste In the health care setting, this occurs when there is over utilization of services, or other practices that result in unnecessary costs. This spending can be eliminated without reducing the quality of care. 8

9 Defining Fraud, Waste, and Abuse Abuse Improper behaviors or billing practices that create unnecessary costs. The state of mind is what separates fraud from abuse. The result is still an unauthorized benefit. 9

10 RECOGNIZING Fraud Waste Abuse 10

11 Recognizing Fraud, Waste and Abuse Examples MA Organizations and Part D Sponsors Failing to provide medically necessary services Offering beneficiaries cash to induce them to enroll in certain programs Discriminating against beneficiaries because of illness category Inappropriate formulary decisions based on costs rather than clinical appropriateness 11

12 Recognizing Fraud, Waste and Abuse Examples Pharmacies Billing for brand named drugs when generics are dispensed Billing for non covered prescriptions as covered Prescription splitting Dispensing expired prescriptions Manipulating True Out of Pocket costs (TROOP) 12

13 Recognizing Fraud, Waste and Abuse Examples Providers Illegal payment schemes Prescription Drug Switching (i.e. offering the prescriber a benefit to prescribe certain medications over others) Falsifying information Unnecessary treatment Billing for services not rendered Double billing Upcoding Unbundling Altering claim forms 13

14 Recognizing Fraud, Waste and Abuse Examples Pharmacy Benefit Managers (PBM s) Prescription drug switching Unlawful payment for steering a beneficiary toward a certain plan, drug or formulary placement Inappropriate formulary decisions Drug splitting and/or shorting Failure to offer negotiated prices 14

15 Recognizing Fraud, Waste and Abuse Examples Beneficiaries Use of another person s Medicare card to get medical care, supplies, or equipment Providing false statements on an enrollment application Using a false address to obtain coverage when your primary address is out of the service area 15

16 PREVENTING Fraud Waste Abuse 16

17 CMS Control of Fraudulent Activities: Close coordination with contractors, providers and law enforcement agencies Strict Medicare Program compliance requirements that protect stakeholders Applying fair and firm enforcement policies Using data analysis and medical review to detect violations early Educating physicians, providers, suppliers, andbeneficiaries 17

18 PREVENTION TIPS Monitor Exclusion Lists: Check the Office of Inspector General (OIG) and General Services Administration (GSA) lists for all new employees and at least annually thereafter to ensure that employees and other entities that assist in the administration or delivery of services to Medicare beneficiaries are not included on such lists. OIG List of Excluded Individuals/Entities (LEIE): p// g / General Services Administration (GSA) database of excluded individuals/entities: 18

19 PREVENTION TIPS cont'd Communicate with staff and colleagues Open communication in exit interviews i to uncover compliance issues Take action, report Have a compliance program Carefully monitor claims for accuracy Perform medical record reviews Conduct regular internal audits Implement written policies and procedures Conduct effective training and education Enforce standards through well published disciplinary guidelines Corrective Action 19

20 PREVENTION TIPS cont'd For Beneficiaries: Report suspected instances of fraud Review payment notices for errors (make sure Medicare was not billed for services, supplies or equipment not received) Do not contact a physician to request a service you do not need Be cautious of providers who claim they have been endorsed by the Federal government or by Mdi Medicare 20

21 RELEVANT LAWS 21

22 Deficit Reduction Act of 2005 A provision of the Deficit Reduction Act of 2005 (DRA) requires entities that receive at least $5 million in payments py from a federal or state health plan, including Medicare or Medicaid, to establish written policies describing: federal and state false fl claims statutes; federal and state whistleblower protections; and the entity s policy for preventing and detecting fraud, waste, and abuse in federal and state health care programs. 22

23 Federal False Claims Statutes Federal False Claims Act, 31 U.S.C Program Fraud Civil Remedies Act 31 U.S.C Qui Tam Whistleblower Provisions, 31 USC U.S.C

24 Federal False Claims Act Imposes liability on any person who: knowingly files a false or fraudulent claim for repayment or approval knowingly makes oruses a false record or statement to obtain payment on a false or fraudulent claim; knowingly makes or uses a false record or statement to conceal, avoid, or decrease an obligation to pay or transmit money to the government; or conspires to defraud a federal program. 24

25 Federal False Claims Act cont d Knowingly is defined to mean that a person has actual knowledge of the information in the claim; acts in deliberate ignorance ofthetruth truth orfalsity ofthe information in the claim; or acts in reckless disregard ofthe truthorfalsity oftheinformation in the claim. 25

26 Federal False Claims Act cont d Potential liability under the FCA includes penalties ranging from $5,500 to $11,000 per claim. In addition, the health plan can be required to pay three times the amount of damages sustained by the U.S. government. The OIG may also seek to exclude the health plan from participation in federal health care programs. 26

27 Program Fraud Civil Remedies Act The Program Fraud Civil Remedies Act is a federal statute that provides additional penalties for improper claims and improper statements, including $5,000per false claim plus twotimes the amount of the claim. A person violates the Act if they know, or have reason to know, they are submitting a claim that is: false, fictitious, or fraudulent; includes or is supported by written statements that are false, fictitious, or fraudulent; includes or is supported by a written statement that omits a material fact which makes the statement false as a result; or for payment for property or services not provided as claimed. 27

28 Whistleblower Protection To encourage individuals to come forward and report misconduct involving false claims, the Federal False Claims Act includesa qui tam or whistleblower provision. This provision allows a person with actual knowledge of allegedly false claims li to the government to file a lawsuit on bhlf behalf of the U.S. government. 28

29 Whistleblower Protection cont d The whistleblower must file his or her lawsuit on behalf of the government in federal district court. The lawsuit will be kept confidential while the government reviews and investigates the allegations contained in the lawsuit and decides how to proceed. If the government decides to intervene, the prosecution of the lawsuit will be directed by the U.S. Department of Justice. If the government decides not to intervene, the whistleblower can continue with the lawsuit on his or her own. 29

30 Whistleblower Protection cont d Whistleblowers are protected from retaliation by their employers. They may not be discharged, demoted, suspended, threatened, harassed or discriminated against in the terms and conditions of employment because of lawful actions taken by the employee in connection with an action under the FCA. 30

31 Whistleblower Protection cont d If the lawsuit is successful, the whistleblower may receive an award of up to 30% of the amount recovered. The whistleblower may also be entitled to expenses including attorneys fees and costs of bringing the lawsuit. Also, additional relief may be awarded, including employment reinstatement, back pay, and any other compensation arising from retaliatory conduct against a whistleblower for filing an action under the False Claims Act. 31

32 Fraud Enforcement and Recovery Act of 2009 expands the scope of potential FCA liability by eliminating the presentment requirement 32

33 Patient Protection and Affordable Care Act (2010 Changes to FCA) Changes to the Public Disclosure Bar Original Source Requirement Overpayments Statutory Anti Kickback Liability 33

34 Indiana False Claims Statutes Indiana False Claims Act, I.C Indiana State Whistleblower Provision, I.C

35 Indiana False Claims Act The Indiana False Claims Act imposes liability on any person who knowingly orintentionally: presents a false claim to the state for payment or approval; makes or uses a false record or statement to obtain payment or approval of a false claim from the state; with the intent to defraud the state, delivers less money or property to the state than the amount recorded or authorizes issuance of a receipt without knowing the information is true; or makes or uses a false record or statement to avoid an obligation to pay or transmit property to the state. 35

36 Indiana False Claims Act cont d A violation of this provision carries a penalty of $5,000 for each such improper claim. In addition, the health plan can be required to pay three times the amount of damages sustained by the state. 36

37 Indiana Whistleblower Provision An employee of a private employer that is under public contract may report in writing the existence of: a violation of federal law or regulation; a violation of a state law or rule; a violation of an ordinance of a political subdivision; or the misuse or public resources. 37

38 Indiana Whistleblower Provision cont d For having made a report, the employee may not suffer retaliation including dismissal, denial of salary increases or benefits, transfer or reassignment, denial of promotion, or demotion. If the lawsuit is successful, the whistleblower may receive an award of up to 30% of the amount recovered. The whistleblower may also be entitled to expenses including attorneys fees and costs of bringing the lawsuit. 38

39 Anti Kickback Laws Federal Law 1) Prohibits knowingly and willfully committing fraud 2) Prohibition on offering, paying, soliciting, or receiving any renumeration 3) Prohibition on providing inducements or rewards in connection with patient referrals Penalties 1) Mandatory exclusion from programs 2) Criminal penalties (prison, $25,000 fine) 3) Civil penalties, possible exclusion Exceptions 1) Safe Harbors (bona fide personal services contract, t proper rebate bt program) 39

40 REPORTING Fraud Waste Abuse 40

41 Reporting Fraud, Waste and Abuse Office of the Inspector General Telephone: HHS TIPS ( ) TTY: gov Centers for Medicare & Medicaid Services (CMS) Tl Telephone: MEDICARE ( ) 41

42 IU Health Plans Reporting Procedures IU Health Plans is committed to complying with all laws governing its operations. IU Health Plans has anonymous and non retaliatory procedures for the reporting of concerns regarding improper conduct. 42

43 IU Health Plans Reporting Procedures cont d IUHealthPlansemployees,representatives,membersorotherparties can report potential violations of the organization s compliance policies orof federal or state health care program requirements throughthe Indiana University Health Trustline at trust36 ( ) Please be aware that although this is anonymous reporting, you must leave information that is specific enough to follow up with investigation. 43

44 IU Health Plans Reporting Procedures cont d Matters can also be reported directly to the IU Health Plans Compliance Director at Matters reported through the Compliance Line, Compliance Director, Compliance Committee or other communication sources will be documented and investigated promptly to determine their truthfulness and significance. 44

45 IU Health Plans Reporting Procedures cont d IU Health Plans will periodically include information on prescription drug fraud, waste and abuse in its newsletters and other membership information packages. Further, to screen enrollee complaints, IU Health Plans will provide a timely hearing and resolve grievances between enrollees and IU health Plans, its employees, or representatives. 45

46 FOR ADDITIONAL INFORMATION: 1. Fraud, Waste and Abuse Training Clarification, Kimberly Brandt, Director, Program Integrity Group, CMS, Office of Financial Management, August 21, Medicare Fraud, Medicare Fraud Prevention and Detection Tips, April 17, Internal/External Strategies for Managing Risk and Dealing with Government Enforcement Agencies, Medicare Marketing Summit, Marci Handler, Epstein, Becker, & Green, March 16, Medicare Advantage Prescription Drug Fraud, Waste and Abuse Training, HealthCare Administrative Solutions, Inc. (HCAS), September 9, RESOURCES: 1. Office of Inspector General 2. Prescription Drug Benefit Manual, Chapter 9, Part D Program to Control Fraud, Waste and Abuse 3. Code of Federal Regulations 4. stats DoJ 2008.pdf Comprehensive information regarding FCA statistics can also be found at including information on recoveries in individual cases

47 Thank You! 47

SCAN Health Plan Policy and Procedure Number: CRP-0067, False Claims Act & Deficit Reduction Act 2005

SCAN Health Plan Policy and Procedure Number: CRP-0067, False Claims Act & Deficit Reduction Act 2005 Health Plan Policy and Procedure Number: CRP-0067, False Claims Act & Deficit Reduction Act 2005 Approver Approval Stage Date Chris Zorn Approval Event (Authoring) 12/09/2013 Nancy Monk Approval Event

More information

FRAUD, WASTE & ABUSE. Training for First Tier, Downstream and Related Entities. Slide 1 of 24

FRAUD, WASTE & ABUSE. Training for First Tier, Downstream and Related Entities. Slide 1 of 24 FRAUD, WASTE & ABUSE Training for First Tier, Downstream and Related Entities Slide 1 of 24 Purpose of this Program On December 5, 2007, the Centers for Medicare and Medicaid Services ( CMS ) published

More information

55144-1-5 Page: 1 of 5. Pharmacy Fraud, Waste and Abuse Policy. 1.0 Compliance Assurance. 2.0 Procedure

55144-1-5 Page: 1 of 5. Pharmacy Fraud, Waste and Abuse Policy. 1.0 Compliance Assurance. 2.0 Procedure Pharmacy Fraud, Waste and Abuse Policy 1.0 Compliance Assurance This Fraud Waste and Abuse Policy ( Policy ) reiterates the commitment of this pharmacy to comply with the standards of conduct established

More information

False Claims / Federal Deficit Reduction Act Notice Help Stop Healthcare Fraud, Waste and Abuse: Report to the Firelands Corporate Compliance Officer

False Claims / Federal Deficit Reduction Act Notice Help Stop Healthcare Fraud, Waste and Abuse: Report to the Firelands Corporate Compliance Officer 1111 Hayes Avenue Sandusky, OH 44870 www.firelands.com False Claims / Federal Deficit Reduction Act Notice Help Stop Healthcare Fraud, Waste and Abuse: Report to the Firelands Corporate Compliance Officer

More information

This policy applies to UNTHSC employees, volunteers, contractors and agents.

This policy applies to UNTHSC employees, volunteers, contractors and agents. Policies of the University of North Texas Health Science Center 3.102 Detecting and Responding to Fraud, Waste and Abuse Chapter 3 Compliance Policy Statement UNTHSC developed and implemented a Compliance

More information

False Claims Act CMP212

False Claims Act CMP212 False Claims Act CMP212 Colorado Access is committed to a culture of compliance in which its employees, providers, contractors, and consultants are educated and knowledgeable about their role in reporting

More information

POLICY AND STANDARDS. False Claims Laws and Whistleblower Protections

POLICY AND STANDARDS. False Claims Laws and Whistleblower Protections POLICY AND STANDARDS Corporate Policy Applicability: Magellan BH (M) NIA (N) ICORE (I) Magellan Medicaid Administration (A) Corporate Policy: Policy Number: Policy Name: Date of Inception: January 1, 2007

More information

USC Office of Compliance

USC Office of Compliance PURPOSE This policy complies with requirements under the Deficit Reduction Act of 2005 and other federal and state fraud and abuse laws. It provides guidance on activities that could result in incidents

More information

Title: Preventing and Reporting Fraud, Waste and Abuse in Federal Health Care Programs. Area Manual: Corporate Compliance Page: Page 1 of 10

Title: Preventing and Reporting Fraud, Waste and Abuse in Federal Health Care Programs. Area Manual: Corporate Compliance Page: Page 1 of 10 Title: Preventing and Reporting Fraud, Waste and Abuse in Federal Health Care Programs Area Manual: Corporate Compliance Page: Page 1 of 10 Reference Number: I-70 Effective Date: 10/02 Contact Person:

More information

To: All Vendors, Agents and Contractors of Hutchinson Regional Medical Center

To: All Vendors, Agents and Contractors of Hutchinson Regional Medical Center To: All Vendors, Agents and Contractors of Hutchinson Regional Medical Center From: Corporate Compliance Department Re: Deficit Reduction Act of 2005 Dear Vendor/Agent/Contractor: Under the Deficit Reduction

More information

Fraud Waste and Abuse Training First Tier, Downstream and Related Entities. ONECare by Care1st Health Plan Arizona, Inc. (HMO) Revised: 10/2009

Fraud Waste and Abuse Training First Tier, Downstream and Related Entities. ONECare by Care1st Health Plan Arizona, Inc. (HMO) Revised: 10/2009 Fraud Waste and Abuse Training First Tier, Downstream and Related Entities ONECare by Care1st Health Plan Arizona, Inc. (HMO) Revised: 10/2009 Overview Purpose Care1st/ ONECare Compliance Program Definitions

More information

policy (C) Deficit Reduction Act of 2005 and the Federal False Claims Act

policy (C) Deficit Reduction Act of 2005 and the Federal False Claims Act Name of Policy: Detecting and Preventing Fraud, Waste and Abuse Policy Number: 3364-15-02 Issuing Office: President Responsible Agent: Compliance/Privacy Officer Revision date: July 5, 2011 Original effective

More information

NewYork-Presbyterian Hospital Sites: All Centers Hospital Policy and Procedure Manual Number: D160 Page 1 of 9

NewYork-Presbyterian Hospital Sites: All Centers Hospital Policy and Procedure Manual Number: D160 Page 1 of 9 Page 1 of 9 TITLE: FEDERAL DEFICIT REDUCTION ACT OF 2005 FRAUD AND ABUSE PROVISIONS POLICY: NewYork- Presbyterian Hospital (NYP or the Hospital) is committed to preventing and detecting any fraud, waste,

More information

CHAMPAIGN COUNTY NURSING HOME SUMMARY OF ANTI-FRAUD AND ABUSE POLICIES

CHAMPAIGN COUNTY NURSING HOME SUMMARY OF ANTI-FRAUD AND ABUSE POLICIES 1. PURPOSE CHAMPAIGN COUNTY NURSING HOME SUMMARY OF ANTI-FRAUD AND ABUSE POLICIES Champaign County Nursing Home ( CCNH ) has established anti-fraud and abuse policies to prevent fraud, waste, and abuse

More information

ADMINISTRATION POLICY MEMORANDUM

ADMINISTRATION POLICY MEMORANDUM ADMINISTRATION POLICY MEMORANDUM POLICY TITLE: FRAUD AND ABUSE POLICY NUMBER: JCAHO FUNCTION AREA: POLICY APPLICABLE TO: POLICY EFFECTIVE DATE: POLICY REVIEWED: MCH-1083 Leadership All Employees January

More information

Metropolitan Jewish Health System and its Participating Agencies and Programs [MJHS]

Metropolitan Jewish Health System and its Participating Agencies and Programs [MJHS] Metropolitan Jewish Health System and its Participating Agencies and Programs [MJHS] POLICY PURSUANT TO THE FEDERAL DEFICIT REDUCTION ACT OF 2005: Detection and Prevention of Fraud, Waste, and Abuse and

More information

TM Nightingale. Home Healthcare. Fraud & Abuse: Prevention, Detection, & Reporting

TM Nightingale. Home Healthcare. Fraud & Abuse: Prevention, Detection, & Reporting Fraud & Abuse: Prevention, Detection, & Reporting What Is Fraud? Fraud is defined as making false statements or representations of facts to obtain benefit or payment for which none would otherwise exist.

More information

PITTSBURGH CARE PARTNERSHIP, INC. COMMUNITY LIFE PROGRAM POLICY AND PROCEDURE MANUAL. False Claims Act Explanation and Reporting Requirements

PITTSBURGH CARE PARTNERSHIP, INC. COMMUNITY LIFE PROGRAM POLICY AND PROCEDURE MANUAL. False Claims Act Explanation and Reporting Requirements SUBJECT: False Claims Act Explanation and Reporting Requirements NUMBER: 1004 CROSS REFERENCE NUMBER: 1823 REG. REF.: 31 U.S.C. 37-29 PURPOSE: POLICY: The purposes of this policy are to describe the Federal

More information

False Claims Act NUMBER NH-LD-CP-220 Last Revised/Reviewed TITLE. Apr13. LD, CP Corporate Wide TJC FUNCTIONS APPLIES TO I.

False Claims Act NUMBER NH-LD-CP-220 Last Revised/Reviewed TITLE. Apr13. LD, CP Corporate Wide TJC FUNCTIONS APPLIES TO I. ADMINISTRATIVE TITLE False Claims Act NUMBER NH-LD-CP-220 Last Revised/Reviewed Effective Date: TJC FUNCTIONS APPLIES TO LD, CP Corporate Wide Apr13 I. SCOPE / PURPOSE It is the policy of Novant Health

More information

Fraud, Waste and Abuse Prevention and Education Policy

Fraud, Waste and Abuse Prevention and Education Policy Corporate Compliance Fraud, Waste and Abuse Prevention and Education Policy The Compliance Program at the Cortland Regional Medical Center (CRMC) demonstrates our commitment to uphold all federal and state

More information

A summary of administrative remedies found in the Program Fraud Civil Remedies Act

A summary of administrative remedies found in the Program Fraud Civil Remedies Act BLACK HILLS SPECIAL SERVICES COOPERATIVE'S POLICY TO PROVIDE EDUCATION CONCERNING FALSE CLAIMS LIABILITY, ANTI-RETALIATION PROTECTIONS FOR REPORTING WRONGDOING AND DETECTING AND PREVENTING FRAUD, WASTE

More information

Compliance and Program Integrity Melanie Bicigo, CHC, CEBS mlbicigo@uphp.com 906-225-7749

Compliance and Program Integrity Melanie Bicigo, CHC, CEBS mlbicigo@uphp.com 906-225-7749 Compliance and Program Integrity Melanie Bicigo, CHC, CEBS mlbicigo@uphp.com 906-225-7749 Define compliance and compliance program requirements Communicate Upper Peninsula Health Plan (UPHP) compliance

More information

Fraud, Waste and Abuse Training for Medicare and Medicaid Providers

Fraud, Waste and Abuse Training for Medicare and Medicaid Providers Fraud, Waste and Abuse Training for Medicare and Medicaid Providers For Use By: Licensed affiliates and subsidiaries of Magellan Health Services, Inc. Contents and Agenda Define Fraud, Waste, and Abuse

More information

TENNCARE POLICY MANUAL

TENNCARE POLICY MANUAL TENNCARE POLICY MANUAL Policy No: Pl 08-001 (Rev. 4) Subject: False Claims Act Policy Approval: Date: PURPOSE OF POLICY STATEMENT: The Bureau of TennCare is committed to its role in preventing health care

More information

COMPLIANCE AND OVERSIGHT MONITORING

COMPLIANCE AND OVERSIGHT MONITORING COMPLIANCE AND OVERSIGHT MONITORING The contract between HCA and Molina Healthcare defines a number of performance requirements that must be satisfied by Molina Healthcare subcontracted Providers to provide

More information

Colorado West HealthCare System Grand Junction, CO

Colorado West HealthCare System Grand Junction, CO Policy Title: Effective Date: 1/30/2008 Supersedes Date: N/A Colorado West HealthCare System Grand Junction, CO CWHS-WIDE POLICY FALSE CLAIMS ACT Responsible Departments: All Departments Administration

More information

Policies and Procedures: WVUPC Policy Pursuant to the Requirements of the Deficit Reduction Act of 2005

Policies and Procedures: WVUPC Policy Pursuant to the Requirements of the Deficit Reduction Act of 2005 POLICY/PROCEDURE NO.: B-17 Effective date: Jan. 1, 2007 Date(s) of review/revision: Nov. 1, 2015 Policies and Procedures: WVUPC Policy Pursuant to the Requirements of the Deficit Reduction Act of 2005

More information

Compliance Plan False Claims Act & Whistleblower Provisions Purpose/Policy/Procedures

Compliance Plan False Claims Act & Whistleblower Provisions Purpose/Policy/Procedures CATHOLIC CHARITIES OF THE ROMAN CATHOLIC DIOCESE OF SYRACUSE, NY and TOOMEY RESIDENTIAL AND COMMUNITY SERVICES Compliance Plan False Claims Act & Whistleblower Provisions Purpose/Policy/Procedures Purpose:

More information

ADMINISTRATIVE POLICY MANUAL

ADMINISTRATIVE POLICY MANUAL SUPERSEDES: New PAGE: 838.00 POLICY: 1. It is the policy of Onondaga County hereinafter referred to as the County, to comply with all applicable federal, state and local laws and regulations, both civil

More information

VILLAGECARE CORPORATE COMPLIANCE POLICY AND PROCEDURE MANUAL ORIGINAL EFFECTIVE DATE: JANUARY 1, 2007

VILLAGECARE CORPORATE COMPLIANCE POLICY AND PROCEDURE MANUAL ORIGINAL EFFECTIVE DATE: JANUARY 1, 2007 VILLAGECARE CORPORATE COMPLIANCE POLICY AND PROCEDURE MANUAL SUBJECT: COMPLIANCE WITH FEDERAL AND STATE FALSE CLAIMS LAWS AND DETECTION AND PREVENTION OF FRAUD, WASTE AND ABUSE LAST POLICY REVISION EFFECTIVE

More information

Policies and Procedures SECTION:

Policies and Procedures SECTION: PAGE 1 OF 5 I. PURPOSE The purpose of this Policy is to fulfill the requirements of Section 6032 of the Deficit Reduction Act of 2005 by providing to Creighton University employees and employees of contractors

More information

SECTION XII: Fraud, Waste and Abuse

SECTION XII: Fraud, Waste and Abuse FRAUD AND ABUSE Arizona Revised Statute ARS 36-2918.01 requires providers to immediately report suspected fraud and abuse. Members or providers who intentionally deceive or misrepresent in order to obtain

More information

Newport Subacute Healthcare Center

Newport Subacute Healthcare Center Title: False Claims Act Policy Manual: Administrative Policy Manual Category: Business function Approval Signatures: Newport Subacute Healthcare Center Document #: Original Issue: 02/01/2006 Revision Date:

More information

NOYES HEALTH ADMINISTRATION POLICY/PROCEDURE

NOYES HEALTH ADMINISTRATION POLICY/PROCEDURE NOYES HEALTH ADMINISTRATION POLICY/PROCEDURE SUBJECT: DETECTION AND PREVENTION OF POLICY: 200.161 FRAUD, WASTE, AND ABUSE EFFECTIVE DATE: June, 2012 ISSUED BY: Administration TJC REF: None PAGE: 1 OF 5

More information

North Shore LIJ Health System, Inc.

North Shore LIJ Health System, Inc. North Shore LIJ Health System, Inc. POLICY TITLE: Detecting and Preventing Fraud, Waste, Abuse and Misconduct POLICY #: 800.09 System Approval Date: 6/23/14 Site Implementation Date: Prepared by: Office

More information

Policy and Procedure: Corporate Compliance Topic: False Claims Act and Whistleblower Provisions, Deficit Reduction Act

Policy and Procedure: Corporate Compliance Topic: False Claims Act and Whistleblower Provisions, Deficit Reduction Act Policy and Procedure: Corporate Compliance Topic: False Claims Act and Whistleblower Provisions, Deficit Reduction Act SCOPE OF POLICY This policy applies to all CFS employees, including trainees, volunteers,

More information

MEMORIAL HERMANN HEALTH SYSTEM POLICY

MEMORIAL HERMANN HEALTH SYSTEM POLICY Page 1 of 5 MEMORIAL HERMANN HEALTH SYSTEM POLICY POLICY TITLE: False Claims Policy PUBLICATION DATE: 05/23/2014 VERSION: 2 POLICY PURPOSE: To comply with certain requirements set forth in the Deficit

More information

NORTHCARE NETWORK. POLICY TITLE: Deficit Reduction Act (DRA) EFFECTIVE DATE: 1/1/15 REVIEW DATE: New Policy

NORTHCARE NETWORK. POLICY TITLE: Deficit Reduction Act (DRA) EFFECTIVE DATE: 1/1/15 REVIEW DATE: New Policy NORTHCARE NETWORK POLICY TITLE: Deficit Reduction Act (DRA) EFFECTIVE DATE: 1/1/15 REVIEW DATE: New Policy RESPONSIBLE PARTY: Chief Executive Officer/Compliance Officer CATEGORY: Compliance BOARD APPROVAL

More information

Behavioral Healthcare, Inc. 155 Inverness Drive West Suite 201 Englewood, CO 80112

Behavioral Healthcare, Inc. 155 Inverness Drive West Suite 201 Englewood, CO 80112 1 of 6 I. Policy: It is the policy of Behavioral Healthcare, Inc. (BHI) that all employees (including management, consultants, contractors, and other agents) shall comply with all applicable Federal and

More information

FEDERAL & NEW YORK STATUTES RELATING TO FILING FALSE CLAIMS

FEDERAL & NEW YORK STATUTES RELATING TO FILING FALSE CLAIMS FEDERAL & NEW YORK STATUTES RELATING TO FILING FALSE CLAIMS I. FEDERAL LAWS False Claims Act (31 USC 3729-3733) The False Claims Act ("FCA") provides, in pertinent part, that: (a) Any person who (1) knowingly

More information

VNSNY CORPORATE. DRA Policy

VNSNY CORPORATE. DRA Policy VNSNY CORPORATE DRA Policy TITLE: FEDERAL DEFICIT REDUCTION ACT OF 2005: POLICY REGARDING THE DETECTION & PREVENTION OF FRAUD, WASTE AND ABUSE AND APPLICABLE FEDERAL AND STATE LAWS APPLIES TO: VNSNY ENTITIES

More information

Prevention of Fraud, Waste and Abuse

Prevention of Fraud, Waste and Abuse Procedure 1910 Responsible Office: Yale Medical Group Effective Date: 01/01/2007 Responsible Department: Administration Last Revision Date: 09/20/2013 Prevention of Fraud, Waste and Abuse Policy Statement...

More information

HERITAGE FARM POLICY AND PROCEDURES. Policy: False Claims Act and Whistleblower Provisions

HERITAGE FARM POLICY AND PROCEDURES. Policy: False Claims Act and Whistleblower Provisions HERITAGE FARM POLICY AND PROCEDURES Policy: False Claims Act and Whistleblower Provisions Date: October 8, 2013 Rationale: It is Heritage Farm s intent to make sure all claims are submitted in a timely

More information

SOUTH NASSAU COMMUNITIES HOSPITAL One Healthy Way, Oceanside, NY 11572

SOUTH NASSAU COMMUNITIES HOSPITAL One Healthy Way, Oceanside, NY 11572 SOUTH NASSAU COMMUNITIES HOSPITAL One Healthy Way, Oceanside, NY 11572 POLICY TITLE: Compliance with Applicable Federal and State False Claims Acts POLICY NUMBER: OF-ADM-232 DEPARTMENT: Hospital-wide CROSS-REFERENCE:

More information

Medicare Compliance and Fraud, Waste, and Abuse Training

Medicare Compliance and Fraud, Waste, and Abuse Training Medicare Compliance and Fraud, Waste, and Abuse Training Objectives Recognize laws and concepts affecting compliance and fraud, waste, and abuse (FWA) Increase awareness of FWA Use identification techniques

More information

5037 Employee Education About False Claims Recovery 5037. The purpose of this policy is to educate employees, contractors, and agents on

5037 Employee Education About False Claims Recovery 5037. The purpose of this policy is to educate employees, contractors, and agents on 5037 Employee Education About False Claims Recovery 5037 The purpose of this policy is to educate employees, contractors, and agents on the requirements of the Deficit Reduction Act (DRA) of 2005 which

More information

Deficit Reduction Act Information for Employees, Contractors and Agents

Deficit Reduction Act Information for Employees, Contractors and Agents Nationally Ranked. Locally Trusted. Denver Health Deficit Reduction Act Information for Employees, Contractors and Agents EFFECTIVE DATE: DECEMBER 31, 2006 PAGE 1 OF 5 Purpose: Provide a written policy

More information

Compliance with False Claims Act

Compliance with False Claims Act MH Policy and Procedure Document Number: MH-COMPLY-001 Document Owner: Corporate Compliance Officer Date Last Author: Corporate Compliance Officer General Description Purpose: To establish written guidelines

More information

COUNTY OF ORANGE. False Claims Act and Whistleblower Provisions Policy and Procedures

COUNTY OF ORANGE. False Claims Act and Whistleblower Provisions Policy and Procedures COUNTY OF ORANGE False Claims Act and Whistleblower Provisions Policy and Procedures COUNTY OF ORANGE FALSE CLAIMS ACT AND WHISTLEBLOWER PROVISIONS POLICY AND PROCEDURES I. Purpose. The County of Orange

More information

Fraud Waste and Abuse Training First Tier, Downstream and Related Entities

Fraud Waste and Abuse Training First Tier, Downstream and Related Entities Fraud Waste and Abuse Training First Tier, Downstream and Related Entities Revised: 04/2010 OVERVIEW Centene Corporation Purpose Bridgeway Compliance Program Definitions of Fraud Waste & Abuse Laws and

More information

fraud, waste, abuse, compliance, integrity, Integrity Help Line

fraud, waste, abuse, compliance, integrity, Integrity Help Line Policy / Procedure: KEY TERMS: fraud, waste, abuse, compliance, integrity, Integrity Help Line I. PURPOSE: To help our employees, agents and contractors understand the methods to prevent and detect fraud,

More information

Medicare Compliance Training and Fraud, Waste, and Abuse Training. Producer Training 2012-2013

Medicare Compliance Training and Fraud, Waste, and Abuse Training. Producer Training 2012-2013 Medicare Compliance Training and Fraud, Waste, and Abuse Training Producer Training 2012-2013 CMS, PHP and You Providence Health Plans (PHP) contracts with the Centers for Medicare & Medicaid Services

More information

Reports of Compliance Concerns and Violations

Reports of Compliance Concerns and Violations The University of Chicago Medical Center Compliance Manual (UCHHS;BSD;UCPP) Reports of Compliance Concerns and Violations Issued: November 1, 1999 Reports of Compliance Concerns and Violations Revised:

More information

Coffee Regional Medical Center FALSE CLAIMS EDUCATION

Coffee Regional Medical Center FALSE CLAIMS EDUCATION Policy/Procedure Department Administration Effective 08/15/2008 Scope Organization Cross Reference Review Date 08/14/2008,12/18/2013 Revision History Signatures Date 12/18/2013 Prepared by Lavonda Cravey

More information

Fraud, Waste & Abuse. Training Course for UHCG Employees

Fraud, Waste & Abuse. Training Course for UHCG Employees Fraud, Waste & Abuse Training Course for UHCG Employees Overview The Centers for Medicare & Medicaid Services (CMS) require Medicare Advantage Organizations and Part D Plan Sponsors to provide annual fraud,

More information

Westlake Convalescent Hospital

Westlake Convalescent Hospital Title: False Claims Act Policy Manual: Administrative Policy Manual Category: Business function Approval Signatures: Westlake Convalescent Hospital Document #: Original Issue: 02/01/2006 Revision Date:

More information

METHODIST HEALTH SYSTEM ADMINISTRATIVE TITLE: DETECTING FRAUD AND ABUSE AND AN OVERVIEW OF THE FEDERAL AND STATE FALSE CLAIMS ACTS

METHODIST HEALTH SYSTEM ADMINISTRATIVE TITLE: DETECTING FRAUD AND ABUSE AND AN OVERVIEW OF THE FEDERAL AND STATE FALSE CLAIMS ACTS METHODIST HEALTH SYSTEM ADMINISTRATIVE Formulated: 6/19/07 Reviewed: Revised: Effective: 10/30/07 TITLE: DETECTING FRAUD AND ABUSE AND AN OVERVIEW OF THE FEDERAL AND STATE FALSE CLAIMS ACTS PURPOSE: Methodist

More information

ADMINISTRATIVE POLICY SECTION: CORPORATE COMPLIANCE Revised Date: 2/26/15 TITLE: FALSE CLAIMS ACT & WHISTLEBLOWER PROVISIONS

ADMINISTRATIVE POLICY SECTION: CORPORATE COMPLIANCE Revised Date: 2/26/15 TITLE: FALSE CLAIMS ACT & WHISTLEBLOWER PROVISIONS Corporate Compliance Plan AD-819-0 Reporting of Compliance Concerns & Non-retaliation AD-807-0 Compliance Training Policy CFC ADMINISTRATIVE POLICY AD-819-1 SECTION: CORPORATE COMPLIANCE Revised Date:

More information

POLICY AND PROCEDURES MANUAL FRAUD, WASTE, AND ABUSE

POLICY AND PROCEDURES MANUAL FRAUD, WASTE, AND ABUSE Page Number: 1 of 7 TITLE: PURPOSE: FRAUD, WASTE, AND ABUSE The Harris County Hospital District implemented a Corporate Compliance Program in an effort to establish effective internal controls that promote

More information

Deficit Reduction Act Employee Information Requirements

Deficit Reduction Act Employee Information Requirements November 9, 2006 Deficit Reduction Act Employee Information Requirements The Deficit Reduction Act ( DRA ) requires states participating in the Medicaid program to amend their State Plans to mandate that

More information

False Claims and Whistleblower Protections All employees, volunteers, students, physicians, vendors and contractors

False Claims and Whistleblower Protections All employees, volunteers, students, physicians, vendors and contractors Policy and Procedure Title: Applies to: False Claims and Whistleblower Protections All employees, volunteers, students, physicians, vendors and contractors Number: First Created: 1/07 SY-CO-019 Issuing

More information

CORPORATE COMPLIANCE: BILLING & CODING COMPLIANCE

CORPORATE COMPLIANCE: BILLING & CODING COMPLIANCE SUBJECT: CORPORATE COMPLIANCE: BILLING & CODING COMPLIANCE MISSION: Quality, honesty and integrity, in everything we do, are important values to all of us who are associated with ENTITY NAME ( ENTITY NAME

More information

Fraud, Waste and Abuse Page 1 of 9

Fraud, Waste and Abuse Page 1 of 9 Page 1 of 9 Overview It is the policy of MVP Health Care, Inc. and its affiliates (collectively referred to as MVP ) to comply with all applicable federal and state laws regarding fraud, waste and abuse.

More information

2012-2013 MEDICARE COMPLIANCE TRAINING EMPLOYEES & FDR S. 2012 Revised

2012-2013 MEDICARE COMPLIANCE TRAINING EMPLOYEES & FDR S. 2012 Revised 2012-2013 MEDICARE COMPLIANCE TRAINING EMPLOYEES & FDR S 2012 Revised 1 Introduction CMS Requirements As of January 1, 2011, Federal Regulations require that Medicare Advantage Organizations (MAOs) and

More information

EDUCATION ABOUT FALSE CLAIMS RECOVERY

EDUCATION ABOUT FALSE CLAIMS RECOVERY Type: MGI Corporate Policy Number: M 700 Effective Date: June 2014 Supersedes: AP 201, 4/12 Revised: 6/14 EDUCATION ABOUT FALSE CLAIMS RECOVERY I. PURPOSE This policy is intended to ensure compliance with

More information

CORPORATE COMPLIANCE POLICIES AND PROCEDURES DRA NOTICE POLICY (CPL-007) Last Revision Date: September 9, 2014

CORPORATE COMPLIANCE POLICIES AND PROCEDURES DRA NOTICE POLICY (CPL-007) Last Revision Date: September 9, 2014 CORPORATE COMPLIANCE POLICIES AND PROCEDURES DRA NOTICE POLICY (CPL-007) Last Revision Date: September 9, 2014 Original Date: March 5, 2013 OMNICARE DRA NOTICE POLICY CPL-007 (SEPTEMBER 2014) I. PURPOSE

More information

Compliance with Applicable Federal and State Laws - False Claims Act and Similar Laws

Compliance with Applicable Federal and State Laws - False Claims Act and Similar Laws Laws - False Claims Act and Similar Laws Purpose The purpose of this policy ( Policy ) is to provide information regarding: the federal and state False Claims Acts ( FCA ), related administrative remedies

More information

M INISTRY H EALTH CARE

M INISTRY H EALTH CARE M INISTRY H EALTH CARE CORPORATE POSITION STATEMENT TITLE: FRAUD AND ABUSE LAWS AND PROTECTIONS Origination Date: December, 2006 DRAFT/REV: December 7, 2007 Effective Date: January, 2007 Scope: Ministry

More information

Fraud, Waste, and Abuse

Fraud, Waste, and Abuse These training materials are divided into three topics to meet the responsibilities stated on the previous pages: Fraud, Waste, Compliance Program Standards of Conduct Although the information contained

More information

Upper Peninsula Health Plan Policy & Procedure

Upper Peninsula Health Plan Policy & Procedure Upper Peninsula Health Plan Policy & Procedure Index #: Effective: 01/01/07 Subject: State and Federal False Claims Revised: 05/18/11 Act, Whistleblower Protections CEO Approval: 01/01/07 Authorized By:

More information

OSF HEALTHCARE FALSE CLAIMS PREVENTION AND WHISTLEBLOWER PROTECTIONS

OSF HEALTHCARE FALSE CLAIMS PREVENTION AND WHISTLEBLOWER PROTECTIONS OSF HEALTHCARE FALSE CLAIMS PREVENTION AND WHISTLEBLOWER PROTECTIONS POLICY: CC-109 It is the policy of OSF HealthCare (OSF) that false, inaccurate or improper claims will not be submitted to any payer.

More information

Fraud, Waste and Abuse Prevention Training

Fraud, Waste and Abuse Prevention Training Fraud, Waste and Abuse Prevention Training The Centers for Medicare & Medicaid Services (CMS) requires annual fraud, waste and abuse training for organizations providing health services to MA or Medicare

More information

Cardinal McCloskey Services Corporate Compliance False Claims Act and Whistleblower Provisions

Cardinal McCloskey Services Corporate Compliance False Claims Act and Whistleblower Provisions Cardinal McCloskey Services Corporate Compliance False Claims Act and Whistleblower Provisions Purpose: Cardinal McCloskey Services is committed to prompt, complete and accurate billing of all services

More information

Federal and State Laws Relating to False Claims and False Statements

Federal and State Laws Relating to False Claims and False Statements Federal and State Laws Relating to False Claims and False Statements The federal False Claims Act, the federal Program Fraud Civil Remedies Act, New York State's False Claims Act and certain other New

More information

2010 Fraud, Waste, and Abuse Training Materials

2010 Fraud, Waste, and Abuse Training Materials 2010 Fraud, Waste, and Abuse Training Materials UnitedHealthcare Medicare Plans Medicare Advantage AARP MedicareComplete Erickson Advantage Evercare Sierra Spectrum Sierra Village Health SM SecureHorizons

More information

0 HealthAlliance. of the ~udsoti vallevtm J / YOUR PARTNERS IN HEALTH

0 HealthAlliance. of the ~udsoti vallevtm J / YOUR PARTNERS IN HEALTH 0 HealthAlliance of the ~udsoti vallevtm J / YOUR PARTNERS IN HEALTH Policy: Compliance with Applicable Federal and State False Claims Acts Initiated: January 1,2010 Reviewed: Revised: Reference: Responsible

More information

EXECUTIVE SUMMARY Compliance Program and False Claims Recovery

EXECUTIVE SUMMARY Compliance Program and False Claims Recovery EXECUTIVE SUMMARY Compliance Program and False Claims Recovery INTRODUCTION: The Federal Deficit Reduction Act of 2005, also known as the DRA, requires that providers give their employees, medical staff,

More information

I. Policy Purpose. II. Policy Statement. III. Policy Definitions: RESPONSIBILITY:

I. Policy Purpose. II. Policy Statement. III. Policy Definitions: RESPONSIBILITY: POLICY NAME: POLICY SPONSOR: FRAUD, WASTE AND ABUSE COMPLIANCE OFFICER RESPONSIBILITY: EFFECTIVE DATE: REVIEW/ REVISED DATE: I. Policy Purpose The purpose of this policy is to outline the requirements

More information

BlueCross BlueShield of Tennessee Senior Care Division and Volunteer State Health Plan

BlueCross BlueShield of Tennessee Senior Care Division and Volunteer State Health Plan BlueCross BlueShield of Tennessee Senior Care Division and Volunteer State Health Plan Fraud Waste and Abuse Training for Providers, First Tier, Downstream and Related Entities Overview The Centers for

More information

FIRST TIER, DOWNSTREAM AND RELATED ENTITIES (FDR) ANNUAL TRAINING

FIRST TIER, DOWNSTREAM AND RELATED ENTITIES (FDR) ANNUAL TRAINING FIRST TIER, DOWNSTREAM AND RELATED ENTITIES (FDR) ANNUAL TRAINING The Compliance Team appreciates your attention and cooperation during this CMS mandated annual training! DEFINITIONS ADVANTAGE utilizes

More information

Developed by the Centers for Medicare & Medicaid Services

Developed by the Centers for Medicare & Medicaid Services Developed by the Centers for Medicare & Medicaid Services Every year millions of dollars are improperly spent because of fraud, waste, and abuse. It affects everyone. Including YOU. This training will

More information

Combating Fraud, Waste, and Abuse

Combating Fraud, Waste, and Abuse Combating Fraud, Waste, and Abuse On-Line Training The information contained in this presentation is intended to prevent and/or combat Fraud, Waste, and Abuse with respect to Medicare and other benefit

More information

DIVISION OF CHILD & FAMILY SERVICES Children s Mental Health Services

DIVISION OF CHILD & FAMILY SERVICES Children s Mental Health Services DIVISION OF CHILD & FAMILY SERVICES Children s Mental Health Services SUBJECT: False Claims Act POLICY NUMBER: 11.70 NUMBER OF PAGES: 5 + Compliance Violation Report form EFFECTIVE DATE: March 16, 2009

More information

COMPLIANCE AND FRAUD, WASTE AND ABUSE

COMPLIANCE AND FRAUD, WASTE AND ABUSE Neighborhood requires compliance with all laws applicable to the organization s business, including insistence on compliance with all applicable federal and state laws dealing with false claims and false

More information

LAKE COUNTY BOARD OF DD/DEEPWOOD BOARD POLICY I. SUBJECT: FALSE CLAIMS PREVENTION AND WHISTLEBLOWER PROTECTION

LAKE COUNTY BOARD OF DD/DEEPWOOD BOARD POLICY I. SUBJECT: FALSE CLAIMS PREVENTION AND WHISTLEBLOWER PROTECTION File: E-11 LAKE COUNTY BOARD OF DD/DEEPWOOD BOARD POLICY Reviewed and Adopted by the Board: Date: February 28, 2011 Signature on file Elfriede Roman, Superintendent I. SUBJECT: FALSE CLAIMS PREVENTION

More information

The term knowing is defined to mean that a person with respect to information:

The term knowing is defined to mean that a person with respect to information: Section 11. Fraud, Waste, and Abuse Introduction Molina Healthcare of [state] maintains a comprehensive Fraud, Waste, and Abuse program. The program is held accountable for the special investigative process

More information

UPDATED. OIG Guidelines for Evaluating State False Claims Acts

UPDATED. OIG Guidelines for Evaluating State False Claims Acts UPDATED OIG Guidelines for Evaluating State False Claims Acts Note: These guidelines are effective March 15, 2013, and replace the guidelines effective on August 21, 2006, found at 71 FR 48552. UPDATED

More information

False Claims Act Policy 650-117 Effective Date 01/01/2007 Compliance Manual

False Claims Act Policy 650-117 Effective Date 01/01/2007 Compliance Manual False Claims Act Policy 650-117 POLICY Monroe County Healthcare Authority is committed to the highest possible standards of ethical, moral and legal business conduct. Prevention of health care fraud, waste

More information

Federal False Claims Act (31 USC 3729 through 3733)

Federal False Claims Act (31 USC 3729 through 3733) I. INTRODUCTION The False Claims Act (FCA) is a federal law that was created to discourage and punish profiteers from providing sub-standard supplies to the Union Army during the Civil War. The FCA was

More information

MONTEFIORE HEALTH SYSTEM ADMINISTRATIVE POLICY AND PROCEDURE SUBJECT: SUMMARY OF FEDERAL AND STATE NUMBER: JC31.1 FALSE CLAIMS LAWS

MONTEFIORE HEALTH SYSTEM ADMINISTRATIVE POLICY AND PROCEDURE SUBJECT: SUMMARY OF FEDERAL AND STATE NUMBER: JC31.1 FALSE CLAIMS LAWS MONTEFIORE HEALTH SYSTEM ADMINISTRATIVE POLICY AND PROCEDURE SUBJECT: SUMMARY OF FEDERAL AND STATE NUMBER: JC31.1 FALSE CLAIMS LAWS OWNER: DEPARTMENT OF COMPLIANCE EFFECTIVE: REVIEW/REVISED: SUPERCEDES:

More information

Touchstone Health Training Guide: Fraud, Waste and Abuse Prevention

Touchstone Health Training Guide: Fraud, Waste and Abuse Prevention Touchstone Health Training Guide: Fraud, Waste and Abuse Prevention About the Training Guide Touchstone is providing this Fraud, Waste and Abuse Prevention Training Guide as a resource for meeting Centers

More information

ESTABLISHING POLICY AND PROCEDURES FOR COMPLIACE WITH 42 USC 139a(a)(68), False Claims and Whistle Blower Protections

ESTABLISHING POLICY AND PROCEDURES FOR COMPLIACE WITH 42 USC 139a(a)(68), False Claims and Whistle Blower Protections RESOLUTION NO. COA-falseclaimsandwhistlesrev. 93-10 Date: 2/23/2010 ESTABLISHING POLICY AND PROCEDURES FOR COMPLIACE WITH 42 USC 139a(a)(68), False Claims and Whistle Blower Protections BY: Mr. George

More information

THE COUNTY OF MONTGOMERY POLICIES AND PROCEDURES FALSE CLAIMS AND WHISTLEBLOWER PROTECTIONS

THE COUNTY OF MONTGOMERY POLICIES AND PROCEDURES FALSE CLAIMS AND WHISTLEBLOWER PROTECTIONS THE COUNTY OF MONTGOMERY POLICIES AND PROCEDURES POLICY It is the obligation of the County of Montgomery (the County ) to prevent and detect any fraud, waste and abuse in its organization related to Federal

More information

Last Approval Date: May 2008. Page 1 of 12 I. PURPOSE

Last Approval Date: May 2008. Page 1 of 12 I. PURPOSE Page 1 of 12 I. PURPOSE The purpose of this policy is to comply with the requirements in Section 6032 of the Deficit Reduction Act of 2005 (the DRA ), which amends Section 1902(a) of the Social Security

More information

POLICY ON FRAUD, WASTE AND ABUSE IN FEDERAL HEALTH CARE PROGRAMS

POLICY ON FRAUD, WASTE AND ABUSE IN FEDERAL HEALTH CARE PROGRAMS 43 New Scotland Avenue (MC-12) Albany, NY 12208 POLICY ON FRAUD, WASTE AND ABUSE IN FEDERAL HEALTH CARE PROGRAMS EFFECTIVE JANUARY 1, 2007, APPROVED NOVEMBER 14, 2006 LATEST REVISION DATE: MARCH 4, 2015

More information

I. PURPOSE The purpose of this policy is to ensure University HealthCare Alliance ( UHA ) complies with Federal and California False Claims Acts.

I. PURPOSE The purpose of this policy is to ensure University HealthCare Alliance ( UHA ) complies with Federal and California False Claims Acts. Page 1 of 7 I. PURPOSE The purpose of this policy is to ensure University HealthCare Alliance ( UHA ) complies with Federal and California False Claims Acts. II. POLICY STATEMENT UHA will not knowingly

More information

POLICY ON THE FALSE CLAIMS ACTS

POLICY ON THE FALSE CLAIMS ACTS EAST ORANGE GENERAL HOSPITAL COMPLIANCE POLICY Title: Policy on The False Claims Acts Code No.: Section: Corporate Compliance Effective Date: March 1, 2015 Approved by: Compliance Officer Publication Status:

More information

Avoiding Medicaid Fraud. Odyssey House of Utah Questions? Contact your Program Director or Emily Capito, Director of Operations

Avoiding Medicaid Fraud. Odyssey House of Utah Questions? Contact your Program Director or Emily Capito, Director of Operations Avoiding Medicaid Fraud Odyssey House of Utah Questions? Contact your Program Director or Emily Capito, Director of Operations MEDICAID FRAUD OVERVIEW Medicaid Fraud The Medicaid Program provides medical

More information

Federal False Claims Act

Federal False Claims Act Page 1 of 5 False Claims Recovery Policy HMSA must provide information about the following subjects to all HMSA employees and HMSA contractors and agents, who, on behalf of The HMSA Plan for QUEST Members,

More information

MERIDIAN HEALTH ADMINISTRATIVE POLICIES AND PROCEDURES

MERIDIAN HEALTH ADMINISTRATIVE POLICIES AND PROCEDURES ADMINISTRATIVE POLICIES AND PROCEDURES DISTRIBUTION: MERIDIAN TEAM AND BOARD MEMBERS; ALL DIVISIONS, CONTRACTORS AND AGENTS SUBJECT: COMPLIANCE WITH AWARENESS OF FALSE CLAIMS LIABILITY, ANTI-RETALIATION

More information