National Association of Community Health Centers ISSUE BRIEF

Save this PDF as:
 WORD  PNG  TXT  JPG

Size: px
Start display at page:

Download "National Association of Community Health Centers ISSUE BRIEF"

Transcription

1 National Association of Community Health Centers ISSUE BRIEF Medicare/Medicaid Technical Assistance #88 Recent CMS Guidance on Requirements that Providers Educate Employees on False Claims Laws and Policy April 2007 Prepared by: Melinda G. Murray Feldesman Tucker Leifer Fidell, LLP 2001 L Street, N.W. Second Floor Washington, DC (202) For more information, please contact: Roger Schwartz, JD Director of State Affairs and Legislative Counsel Division of Federal, State, and Public Affairs National Association of Community Health Centers, Inc Eye Street, NW Suite 330 Washington, DC Tele.#: (202) Fax: (202) This publication was supported by Grant/Cooperative Agreement Number U3OCS00209 from the Health Resources Services Administration, Bureau of Primary Health Care (HRSA/BPHC). Its contents are solely the responsibility of the authors and do not necessarily represent the official views of HRSA/BPHC. 1

2 AN UPDATE ON THE DEFICIT REDUCTION ACT OF 2005: CMS Guidance on Employee Education Requirements By Melinda G. Murray Last July, NACHC published Issue Brief #87: More Compliance Sticks and Carrots: The Deficit Reduction Act of 2005 in which we addressed various compliance enforcement provisions, especially Section 6032 which requires that entities that receive more than $5 million in Medicaid funds must provide employee education about false claims recoveries and whistleblower protections. In this Issue Brief, we address the Centers for Medicare and Medicaid Services ( CMS ) guidance on the implementation of that Section in the form of two letters to State Medicaid Directors. 1 By way of background, the Deficit Reduction Act of 2005, which was signed into law on February 1, 2006, contains in Section 6032 of the Act, (Section 1902(a)(68) of the Social Security Act) requirements that any entity that receives or pays more than $5 million in Medicaid payments, as a condition of receiving Medicaid payments, must establish written policies for all employees and for all contractors and agents explaining the Federal False Claims Act 2, along with other Federal and State laws that involve civil or criminal penalties for false claims. The entity must also have policies for uncovering 1 The first letter, issued December 13, 2006 (SMDL #06-024) elaborated on the definitions of entity, employee and contractor in the Act, as well as the effective date and the nature of the policies. The second letter (SMDL #07-003), issued March 22, 2007, came in the form of Frequently Asked Questions, available at (scroll to the March 22, 2007 date) U.S.C The False Claims Act provides civil penalties and damages against anyone who knowingly submits, causes, the submission, or presents a false claim to any U.S. employee or agency for payment or approval, such as a claim for reimbursement under Medicare or Medicaid. A unique feature of the law is the ability of a citizen to bring an action on behalf of the government and share in the recovery ( whistleblower provision. ) Many States have State false claims acts and in fact, States are now incentivized under Section 6031of the DRA to pass their own equivalent of the Federal False Claims Act, especially the whistleblower provisions. If they do, then they will receive a larger share of the Federal Medical Assistance Percentage (FMAP). 2

3 fraud, waste, and abuse, as well as advising an employee of the whistleblower protections under the Federal False Claims Act or State law. Although the effective date of this section of the DRA was January 1, , many providers, especially health centers with multiple sites or subsidiaries that may cross state lines, had questions about how the $5 million threshold would be calculated (on a per location or per organization basis), what type of education would be required, which contractors and agents would be covered, and the degree of contractor compliance required. While CMS has brought more clarity to some of these issues in its two State Medicaid Director letters, there are still unanswered questions. This Issue Brief summarizes the CMS guidance by topic. What kind of entity is required to comply with this education provision? The definition of entity is broad and includes a governmental agency, organization, unit corporation, partnership, or other business arrangement, including any Medicaid managed care organization, whether for profit or not-for-profit, and regardless of the form of the business structure, which receives or makes payments of at least $5 million annually under a State plan approved under title XIX (Medicaid), under a waiver of such plan, or a Title XIX demonstration. How is the $5 million calculated for a health center with multiple locations or sub-units? If the health center is providing services or items at more than one location and receives Medicaid payments for services provided or items supplied at these locations of $5 million or more in the aggregate, then it must comply with Section This is true even if there is more than one provider identification or tax I.D. number 3 Unless a State has an approved request for delayed implementation of the requirements of section 6032, the State Plan Amendment must be submitted by March 31,

4 involved for the different locations or units. It also applies to a health center that is structured as a public health center in which a public entity provides the Medicaid services or health care items, in conjunction with a Section 330-compliant governing board, and receives more than $5 million in Medicaid. How is the yearly $5 million calculated and what s the cut-off date? If the health center received or made payments of $5 million for the Federal fiscal year 06, then it must comply. For each Federal fiscal year (October 1-September 30) after this, the health center that receives or pays $5 million will then have to comply as of the January 1 that follows. 4 In calculating the total amount annually, a health center can use either the date that the services were performed or the date that the payment was received, as long as that methodology is consistently applied throughout the year. However, it is only payments received that count towards the $5 million, not amounts billed. The patient contribution to care under the State plan (i.e., co-payments and other cost-sharing) does not count towards the $5 million. The entity counts only the amounts received directly from the State Medicaid Agency when calculating the $5 million and not those dollars received from the Medicaid Managed Care Organization ( MCO ) for managed care arrangements for the health center s MCO patients. What about Medicaid MCOs who receive and spend Medicaid money? The annual threshold of $5 million is met by calculating either payments made to providers or payments received from a State plan. So if the Medicaid MCO receives $3 million in payments from the State and makes payments of $2 million, these amounts are not aggregated to see if the Medicaid MCO is an entity under the Act. 4 There is a delay in effective date under Section 6034(e) for some States whose legislatures did not meet in time for the January 1, 2007 effective date. 4

5 What if the health center receives payments from more than one State? There appears to be inconsistency in two of the questions on the issue of whether a health center s sub-units that also furnish Medicaid health care items or services are aggregated to meet the threshold of $5 million that requires employee education. On the one hand, in the answer to FAQ (Frequently Asked Questions) #5, CMS states that for compliance with Section 6032, an entity is the largest separate organizational unit (i.e. the health center) that provides Medicaid items or services and includes all sub-units of that organizational unit that furnish Medicaid services and items, even if the components are separately incorporated or located in different States. Unless it is part of a health system, each organizational unit is separate for determining whether the $5 million threshold has been met, therefore requiring employee education. If the health center is part of a health system or itself is considered a health system, the entire organization is considered an entity for purposes of compliance with Section On the other hand, in questions 18 and 20, when asked whether payments from multiple States are aggregated to meet the $5 million threshold, CMS s answer is no, payments from multiple States are not aggregated to reach the $5 million threshold, unless it is a health system that is the corporate parent or itself provides Medicaid health care items or services. We think that the answer to question 18 is correct: payments should not be aggregated since each State plan is different, but the apparent conflict needs further clarification, especially with respect to how a health center with subsidiaries might be regarded. NACHC will attempt to obtain an answer to the question of whether payments from different States should be aggregated and whether the health center is considered a health system. Pending a definitive answer, a health center that is 5

6 unsure about whether it meets the $5 million threshold for the requirement of employee education as a result of aggregating sites in different states should conduct the education recommended in this Issue Brief. It is clear that once the health center receives $5 million under one State s Medicaid State plan or waiver program, the health center must provide the education to all of its employees even if the employees are in different States. Do Medicare payments count? Medicare payments are not considered in determining whether a health center has to comply with Section 6032, but if a State agency pays deductibles for dual-eligible individuals and Qualified Medicare Beneficiaries, then those amounts should be considered in connection with whether the health center must comply. What kind of training and education does the health center have to conduct? Section 6032 requires employee education in the form of information about policies and does not require in-person training, although we recommend in-services as the most effective way to educate employees. A health center must disseminate its policies and procedures relating to the detection of fraud, waste, and abuse, the elements of laws such as the False Claims Act, and the rights and protections of whistleblowers in writing or electronically. The health center may insert these policies into the employee handbook, if it has a handbook. However, it is not necessary to create a handbook if one does not exist. It may make the policies available on the intranet and/or distribute them at an employee s initial orientation. How far does a health center have to go in insuring compliance of its contractors and vendors? One of the major questions that many health centers and other providers had about Section 6032 was the requirement that the employee education 6

7 and policies apply to contractors. The contractor or vendor who is covered by these requirements is one which or who, on behalf of the entity: 1) furnishes or otherwise authorizes the furnishing of Medicaid health care items or services; 2) performs billing and coding functions; or 3) is involved in the monitoring of health care provided by the entity. It does not include janitors, grounds maintenance personnel, or insurance agents, but it does include contracted physicians, therapists, pharmacies, behavioral health providers, billing companies, and performance improvement consultants. CMS requires that the elements of the law be incorporated into each State s provider enrollment agreements. Unless a State has been given delayed implementation, it is required to amend the State Plan to set forth the manner by which it will ensure an entity s compliance with the Section by March 31, In addition, the State has to describe how it will ensure compliance oversight and the frequency with which it will reassess compliance going forward. CMS may also audit the entities and review a State s procedures though its own routine oversight of States. Although CMS does not require any particular language in the contract itself, the Medicaid State Plan might include requirements to ensure compliance with Section We recommend that if the State has not spoken about particular provisions and if the contract does not already have language about compliance with health center policies, a health center should: 1) Insert language in new contracts requiring compliance with health center policies with specific reference to policies that relate to fraud, waste, and abuse. 7

8 2) For existing contracts, draft a simple amendment containing the language. The policies and procedures that relate to detecting fraud, waste, and abuse, as well as the protection of whistleblowers that are distributed to employees should also be distributed to the contractors. It is up to the health center to determine what distribution method works best for its employees, agents, and contractors. The contractor does not have to actually adopt the health center policies that are implemented to detect and prevent fraud, waste, and abuse, but it is required to cooperate. For example, if the health center conducts audits of particular claims, then a contractor, such as a laboratory services company, would have to participate in the audit of laboratory claims. Does a health center that receives money from a Medicaid MCO comply as an entity or as a contractor? If the health center receives $5 million per year from a State Medicaid Agency directly, it would be considered an entity regardless of whether it also contracts with a Medicaid MCO. If it is a contractor of a Medicaid MCO which meets the $5 million threshold, then the health center is in the position of having to comply as a contractor, too. So a health center could be put in the position of having to adhere to two different sets of policies its own and the Medicaid MCO s. Will CMS provide model policies? CMS has said it will not provide sample policies or model language to comply with Section But NACHC has sample policies attached to Issue Brief # 87 [Listed as out of stock on website]. What are the penalties for non-compliance? Each State will determine how it will oversee and enforce compliance, but a State could decide to discontinue a health center s participation in Medicaid, if it does not comply. The DRA requirements must be 8

9 incorporated into each State provider enrollment agreement and a State Plan amendment is required which could set forth additional penalties. Unanswered Questions. CMS has not provided answers to the following: 1) If an entity such as a health center has subsidiaries or locations in different states, will the amounts received by those sub-units or locations be aggregated to reach the $5 million threshold so that the health center will have to comply with the employee education provisions? (See previous discussion on this issue on p. 4) 2) What policies on the detection of fraud, waste, and abuse are sufficient? 3) What happens if as a contractor to several, or even one, Medicaid MCOs, the health center has to comply with its own policies, as well as possibly conflicting policies in its capacity as contractor to the Medicaid MCO? Recommendations: If a health center has to comply with Section 6032, it should: 1) Make sure its policies describe the Federal False Claims Act, Civil Monetary Penalties Law, administrative remedies, and State laws that provide remedies for false claims [These were also in NACHC Issue Brief #87] 2) Conduct in-person training of employees, agents and contractors about the policies regarding fraud, waste, and abuse and whistleblower rights. 5 3) Ensure that health center policies, whether in an employee handbook or elsewhere, have a well understood procedure to make compliance issues known to 5 Although Section 6032 does not require in-person training, we believe that dissemination of policies is ineffective unless training accompanies the policies. 9

10 the compliance officer or CEO, including an anonymous hot line, while advising the employee of his/her rights and protections as a whistleblower. 6 4) Set forth certain standards regarding billing and coding (such as billing for medically necessary, documented services only, no upcoding, no double billing). 5) Explain in the policies the way the health center prevents and detects fraud. 6) The contracts with all billing and coding vendors, contractors who provide Medicaid services and/or supplies, and contractors who monitor health center quality should be reviewed to make sure they require compliance with health center policies, including those relating to fraud, waste, and abuse and whistleblower rights. If the contracts do not have that language, they should be amended. 6 While requiring the employee to come to the compliance officer first probably cannot be made a condition of employment, employees should certainly be encouraged to seek resolution of the issue first within the health center, before exercising his or her rights as a whistleblower. 10

AHCA MEMBER GUIDANCE IMPLEMENTING THE FALSE CLAIMS ACT EDUCATIONAL PROVISIONS OF THE DEFICIT REDUCTION ACT

AHCA MEMBER GUIDANCE IMPLEMENTING THE FALSE CLAIMS ACT EDUCATIONAL PROVISIONS OF THE DEFICIT REDUCTION ACT AHCA MEMBER GUIDANCE IMPLEMENTING THE FALSE CLAIMS ACT EDUCATIONAL PROVISIONS OF THE DEFICIT REDUCTION ACT THE TOPIC: Section 6033 of the Deficit Reduction Act of 2005 ( DRA ) requires entities that make

More information

Fraud, Waste & Abuse DEFICIT REDUCTION ACT OF 2005. Presented by: MARCH Vision Care, 2013

Fraud, Waste & Abuse DEFICIT REDUCTION ACT OF 2005. Presented by: MARCH Vision Care, 2013 Fraud, Waste & Abuse DEFICIT REDUCTION ACT OF 2005 Presented by: MARCH Vision Care, 2013 DISCLAIMER This training was created as a guide by MARCH and shall not be construed to contain all contractual requirements

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

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

Department of Health Services

Department of Health Services State of California-Health and Human Services Agency Department of Health Services California Department of Health Services SANDRA SHEWRY Director ARNOLDSCHWARZENEGGER Governor DATE MAR 092007 MMCD All

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

Overview of the Deficit Reduction Act and State False Claims

Overview of the Deficit Reduction Act and State False Claims Overview of the Deficit Reduction Act and State False Claims Massachusetts Extended Care Federation Lombardo's, Randolph, Massachusetts June 14, 2007 C. Elizabeth O Keeffe Foley & Lardner LLP Attorney

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

Federal Regulatory Policy Report. Medicare and Medicaid Electronic Health Records Incentives: Reassigning Payments

Federal Regulatory Policy Report. Medicare and Medicaid Electronic Health Records Incentives: Reassigning Payments Federal Regulatory Policy Report Medicare and Medicaid Electronic Health Records Incentives: Reassigning Payments October 2010 COPYRIGHT OCTOBER 2010 National Association of Community Health Centers, 2010

More information

AUG 1 7 2007. Enclosed for your records is an approved copy of the following State Plan Amendment (SPA).

AUG 1 7 2007. Enclosed for your records is an approved copy of the following State Plan Amendment (SPA). Department of Health & Human Services Centers for Medicare & Medicaid Services 233 North Michigan Avenue, Suite 600 Chicago, Illinois 60601-55 19 CEWFffS for MEDJICffE & MEDlC4lD SERVICES AUG 1 7 2007

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

SUSPICIOUS ACTIVITY DETECTION AND BILLING INVESTIGATIONS

SUSPICIOUS ACTIVITY DETECTION AND BILLING INVESTIGATIONS SUSPICIOUS ACTIVITY DETECTION AND BILLING INVESTIGATIONS New Mexico Medicaid False Claims Act OptumHealth has four core modules related to Recovery and Resiliency. These programs provide an overview of

More information

Medicaid Fraud and Abuse Investigations, Prosecutions and Compliance Strategies

Medicaid Fraud and Abuse Investigations, Prosecutions and Compliance Strategies Combating Medicaid Fraud & Abuse: Implications of the Medicaid Integrity Program October 24, 2006 Medicaid Fraud and Abuse Investigations, Prosecutions and Compliance Strategies John T. Bentivoglio jbentivoglio@kslaw.com

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

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

Title: False Claims Act & Whistleblower Protection Information and Education

Title: False Claims Act & Whistleblower Protection Information and Education Care Initiatives Policy and Procedure Title: False Claims Act & Whistleblower Protection Information and Education Version Number Implemented By Revision Date Approved By Approval Date Initial Compliance

More information

The Brody School of Medicine Policy and Procedure Manual

The Brody School of Medicine Policy and Procedure Manual I. Purpose The purpose of this policy is to inform all employees, contractors, and agents of the Brody School of Medicine ( BSOM ) about (i) the federal False Claims Act; (ii) North Carolina Medical Assistance

More information

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

Employee Education About False Claims Recoveries

Employee Education About False Claims Recoveries Employee Education About False Claims Recoveries DHS recommended tools for compliance with Section 6032 of the Deficit Reduction Act (DRA) Affected entities Written standards of conduct Descriptions of

More information

Fraud, Waste and Abuse: Compliance Program. Section 4: National Provider Network Handbook

Fraud, Waste and Abuse: Compliance Program. Section 4: National Provider Network Handbook Fraud, Waste and Abuse: Compliance Program Section 4: National Provider Network Handbook December 2015 2 Our Philosophy Magellan takes provider fraud, waste and abuse We engage in considerable efforts

More information

Fraud, Waste and Abuse Training. Protecting the Health Care Investment. Section Three

Fraud, Waste and Abuse Training. Protecting the Health Care Investment. Section Three Fraud, Waste and Abuse Training Protecting the Health Care Investment Section Three Section 1.2: Purpose According to the National Health Care Anti-Fraud Association, the United States spends more than

More information

Approved by the Audit and Compliance Committee of the Providence Health & Services Board of Directors

Approved by the Audit and Compliance Committee of the Providence Health & Services Board of Directors Integrity and Compliance Description Approved by the Audit Committee of the Providence Health & Services Board of Directors December 7, 2009 Contents: Introduction Page 1 Purpose Page 2 Compliance Administration

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

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

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

The National Association of Community Health Centers, Inc. ISSUE BRIEF

The National Association of Community Health Centers, Inc. ISSUE BRIEF The National Association of Community Health Centers, Inc. ISSUE BRIEF FTC Red Flag Rule Considerations in Developing an Identity Theft Prevention Program April 2009 Prepared for NACHC by: Carrie Bill

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

Integrity. Providence Integrity and Compliance Program Description

Integrity. Providence Integrity and Compliance Program Description Integrity and Compliance Description Approved by the Audit Committee of the Providence Health & Services Board of Directors December 9, 2014 Contents: Introduction Page 1 Purpose Page 2 Compliance Administration

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

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

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

Establishing An Effective Corporate Compliance Program Joan Feldman, Esq. Vincenzo Carannante, Esq. William Roberts, Esq.

Establishing An Effective Corporate Compliance Program Joan Feldman, Esq. Vincenzo Carannante, Esq. William Roberts, Esq. Establishing An Effective Corporate Compliance Program Joan Feldman, Esq. Vincenzo Carannante, Esq. William Roberts, Esq. November 11, 2014 Shipman & Goodwin LLP 2014. All rights reserved. HARTFORD STAMFORD

More information

SECTION 18 1 FRAUD, WASTE AND ABUSE

SECTION 18 1 FRAUD, WASTE AND ABUSE SECTION 18 1 FRAUD, WASTE AND ABUSE Annual FW&A Training Required for Providers and Office Staff 1 Examples of Fraud, Waste and Abuse 2 Fraud, Waste and Abuse Program Policy 3 Suspected Non-Compliance

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

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

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

PREVENTING FRAUD, ABUSE, & WASTE: A Primer for Physical Therapists

PREVENTING FRAUD, ABUSE, & WASTE: A Primer for Physical Therapists PREVENTING FRAUD, ABUSE, & WASTE: A Primer for Physical Therapists Available at: http://www.apta.org/integrity 2014 American Physical Therapy Association. All rights reserved. All reproduction or redistribution

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 CONCEPTS Developed by University of Washington School of Dentistry Staff and Faculty 2016

COMPLIANCE CONCEPTS Developed by University of Washington School of Dentistry Staff and Faculty 2016 COMPLIANCE CONCEPTS Developed by University of Washington School of Dentistry Staff and Faculty 2016 Introduction to Compliance Concepts Welcome to University of Washington School of Dentistry web-based

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

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

Health Care Compliance Association 888-580-8373 www.hcca-info.org

Health Care Compliance Association 888-580-8373 www.hcca-info.org Volume Thirteen Number Five Published Monthly Meet the Co-chairs of HCCA s Upper North East Regional Conference, Caron Cullen and Eric Sandhusen page 13 Feature Focus: What your board needs to know about

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

North American Partners in Anesthesia. Corporate Compliance Plan

North American Partners in Anesthesia. Corporate Compliance Plan North American Partners in Anesthesia Corporate Compliance Plan VERSION EFFECTIVE: JANUARY 2015 CONTENTS Introduction and Mission 1. Corporate Commitment to Compliance: Code of Conduct 2. Written Compliance

More information

UPDATE: THE MEDICARE ADVANTAGE WRAP AROUND PAYMENT FOR FEDERALLY QUALIFIED HEALTH CENTERS (FQHC)

UPDATE: THE MEDICARE ADVANTAGE WRAP AROUND PAYMENT FOR FEDERALLY QUALIFIED HEALTH CENTERS (FQHC) Medicare Technical Assistance ISSUE BRIEF #85 UPDATE: THE MEDICARE ADVANTAGE WRAP AROUND PAYMENT FOR FEDERALLY QUALIFIED HEALTH CENTERS (FQHC) December 2005 Prepared for NACHC by: Adam J. Falk Feldesman

More information

PHI Air Medical, L.L.C. Compliance Plan

PHI Air Medical, L.L.C. Compliance Plan Page No. 1 of 13 Introduction: The PHI Air Medical, L.L.C. is to be used by employees, contractors and vendors to get a high level understanding of the key regulatory requirements relating to our participation

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 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

Understanding Health Reform s

Understanding Health Reform s Compliance 101: Understanding Health Reform s New Compliance Requirements Uri Bilek Feldesman Tucker Leifer Fidell LLP Does your organization have a designated Compliance Officer? a. Yes b. No c. Don't

More information

CORPORATE COMPLIANCE POLICY AND PROCEDURE

CORPORATE COMPLIANCE POLICY AND PROCEDURE Title: Fraud Waste and Abuse Laws in Health Care Policy # 1011 Sponsor: Corporate Compliance Approved by: Carleen Dunne, Director, Corporate Compliance and Privacy Officer Issued: Page: 1 of 7 June 25,

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

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

A Roadmap for New Physicians. Avoiding Medicare and Medicaid Fraud and Abuse

A Roadmap for New Physicians. Avoiding Medicare and Medicaid Fraud and Abuse A Roadmap for New Physicians Avoiding Medicare and Medicaid Fraud and Abuse Introduction This tutorial is intended to assist new physicians in understanding how to comply with Federal laws that combat

More information

SUPPLEMENTAL NOTE ON SUBSTITUTE FOR SENATE BILL NO. 11

SUPPLEMENTAL NOTE ON SUBSTITUTE FOR SENATE BILL NO. 11 Corrected SESSION OF 2007 SUPPLEMENTAL NOTE ON SUBSTITUTE FOR SENATE BILL NO. 11 As Amended by House Committee of the W hole Brief* Sub. for SB 11, as amended by the House Committee of the Whole, would

More information

Fraud, Waste, and Abuse Training. Welcome to the South Florida Community Care Network Fraud, Waste, and Abuse (FWA) & Compliance Training

Fraud, Waste, and Abuse Training. Welcome to the South Florida Community Care Network Fraud, Waste, and Abuse (FWA) & Compliance Training Fraud, Waste, and Abuse Training Welcome to the South Florida Community Care Network Fraud, Waste, and Abuse (FWA) & Compliance Training Training Objectives Meet the regulatory requirement for training

More information

Review of U.S. Coast Guard's FY 2014 Drug Control Performance Summary Report

Review of U.S. Coast Guard's FY 2014 Drug Control Performance Summary Report Review of U.S. Coast Guard's FY 2014 Drug Control Performance Summary Report January 26, 2015 OIG-15-27 HIGHLIGHTS Review of U.S. Coast Guard s FY 2014 Drug Control Performance Summary Report January 26,

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

MEDICAID COMPLIANCE POLICY

MEDICAID COMPLIANCE POLICY 6232 MEDICAID COMPLIANCE POLICY It is the policy of the Board of Education that all school district s practices regarding Medicaid claims for services be in compliance with all applicable federal and state

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

Prepared by: The Office of Corporate Compliance & HIPAA Administration

Prepared by: The Office of Corporate Compliance & HIPAA Administration Gwinnett Health System s Annual Education 2014 Corporate Compliance: Our Commitment to Excellence Prepared by: The Office of Corporate Compliance & HIPAA Administration Objectives After completing this

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

Corporate Compliance and Ethics

Corporate Compliance and Ethics Corporate Compliance and Ethics Title: Corporate Compliance and Ethics Course Code: EL-CCE-COMP-0 Course Outline Section 1: Introduction A. Course Contributors B. About This Course C. Learning Objectives

More information

ADMINISTRATIVE MANUAL Subject: CORPORATE RESPONSIBILITY 21.49. Directive #: 21.49 Present Date: January 2011

ADMINISTRATIVE MANUAL Subject: CORPORATE RESPONSIBILITY 21.49. Directive #: 21.49 Present Date: January 2011 Page: 1 of 18 Directive #: 21.49 Present Date: January 2011 Original Date: September 2004 Review Date: January 2013 Applicable To: SVHC & Affiliated Companies SVMC SCLM SLH FCPC POLICY In furtherance of

More information

Charging, Coding and Billing Compliance 9510-04-10

Charging, Coding and Billing Compliance 9510-04-10 GWINNETT HOSPITAL SYSTEM CORPORATE COMPLIANCE Charging, Coding and Billing Compliance 9510-04-10 Original Date Review Dates Revision Dates 01/2007 05/2009 POLICY Gwinnett Health System, Inc. (GHS), and

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

Compliance Requirements for Healthcare Carriers

Compliance Requirements for Healthcare Carriers INFORMATION DRIVES SOUND ANALYSIS, INSIGHT REGULATORY COMPLIANCE ADVISORY Compliance Requirements for Healthcare Carriers Introduction With the introduction of the new healthcare exchanges in January 2014

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

Compliance. TODAY June 2012. Meet Lanny A. Breuer. Assistant Attorney General, Criminal Division, U.S. Department of Justice.

Compliance. TODAY June 2012. Meet Lanny A. Breuer. Assistant Attorney General, Criminal Division, U.S. Department of Justice. Compliance TODAY June 2012 a publication of the health care compliance association www.hcca-info.org Meet Lanny A. Breuer Assistant Attorney General, Criminal Division, U.S. Department of Justice See page

More information

June 13, 2012. Report Number: A-06-09-00107

June 13, 2012. Report Number: A-06-09-00107 June 13, 2012 OFFICE OF AUDIT SERVICES, REGION VI 1100 COMMERCE STREET, ROOM 632 DALLAS, TX 75242 Report Number: A-06-09-00107 Mr. Don Gregory Medicaid Director Louisiana Department of Health and Hospitals

More information

Health Share of Oregon Compliance Program Self Assessment Tool

Health Share of Oregon Compliance Program Self Assessment Tool Health Share of Oregon Compliance Program Self Assessment Tool Name of Organization: Person Completing Assessment: Date Assessment Completed: Title: 1. Written Policies and Procedures 1.1 Are compliance

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

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

Issue Brief New Medicaid Compliance Issues from the Deficit Reduction Act

Issue Brief New Medicaid Compliance Issues from the Deficit Reduction Act Issue Brief New Medicaid Compliance Issues from the Deficit Reduction Act By Mary Thornton, BSRN, MBA, Mary Thornton & Associates, Inc., National Council Consultant A lot of "noise" accompanied the passage

More information

UMDNJ COMPLIANCE PLAN

UMDNJ COMPLIANCE PLAN UMDNJ COMPLIANCE PLAN INTRODUCTION...2 COMPLIANCE OVERSIGHT 3 COMPLIANCE COMMITTEE STRUCTURE...4 CHIEF COMPLIANCE OFFICER S RESPONSIBILITIES...5 RESEARCH COMPLIANCE.5 UNIT IMPLEMENTATION.6 COMPLIANCE POLICIES

More information

Featured Presentation: Fraud, Waste & Abuse. Copyright 2014 ValueOptions. All rights reserved.

Featured Presentation: Fraud, Waste & Abuse. Copyright 2014 ValueOptions. All rights reserved. Featured Presentation: Fraud, Waste & Abuse 1 ValueOptions Program Integrity 2015 Topics for Today s Presentation Development of Program Integrity, Laws & Requirements Current Audit Activities Preparing

More information

Frequently Asked Questions

Frequently Asked Questions From the New York State Office of the Medicaid Inspector General Web site at www.omig.ny.gov/data/content/view/261/53, last accessed on January 27, 2012 Mandatory Provider Compliance Programs Frequently

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

Fraud, Waste & Abuse Policy

Fraud, Waste & Abuse Policy Fraud, Waste & Abuse Policy Issue Date: Policy approved by the Board of Directors on February, 18, 2015 The Independence Center (The IC) is committed to the responsible stewardship of our resources, and

More information

The United States spends more than $1 trillion each year on healthcare

The United States spends more than $1 trillion each year on healthcare Managed Care Fraud and Abuse Compliance Guidelines I. Introduction The United States spends more than $1 trillion each year on healthcare representing approximately 15 percent of the gross national product.

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

Compliance Department No. COMP.1000.18 Title: EFFECTIVE SYSTEM FOR ROUTINE MONITORING, AUDITING, AND IDENTIFICATION OF COMPLIANCE RISKS (ELEMENT 6)

Compliance Department No. COMP.1000.18 Title: EFFECTIVE SYSTEM FOR ROUTINE MONITORING, AUDITING, AND IDENTIFICATION OF COMPLIANCE RISKS (ELEMENT 6) Page: 1 of 9 I. SCOPE: This policy applies to (1) Tenet Healthcare Corporation and its wholly-owned subsidiaries and affiliates (each, an Affiliate ); and (2) any other entity or organization in which

More information

TENET HEALTHCARE CORPORATION S QUALITY, COMPLIANCE AND ETHICS PROGRAM CHARTER. Updated May 7, 2014

TENET HEALTHCARE CORPORATION S QUALITY, COMPLIANCE AND ETHICS PROGRAM CHARTER. Updated May 7, 2014 TENET HEALTHCARE CORPORATION S QUALITY, COMPLIANCE AND ETHICS PROGRAM CHARTER Updated May 7, 2014 PREAMBLE Tenet Healthcare Corporation ( THC ) hereby sets forth this Charter for its Quality, Compliance

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

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

Compliance Plan False Claims Act & Whistleblower Provisions 1/31/08

Compliance Plan False Claims Act & Whistleblower Provisions 1/31/08 POLICY: CATHOLIC CHARITIES OF THE ROMAN CATHOLIC DIOCESE OF SYRACUSE, NY Compliance Plan False Claims Act & Whistleblower Provisions 1/31/08 Catholic Charities of the Roman Catholic Diocese of Syracuse,

More information

TABLE OF CONTENTS. Claims Processing & Provider Compensation

TABLE OF CONTENTS. Claims Processing & Provider Compensation TABLE OF CONTENTS Claims Address... 2 Claim Submission... 2 Claim Payment... 2 Claim Payment Adjustments.... 2 Claim Disputes... 2 Recovery of Overpayments... 3 Balance Billing... 3 Annual Health Assessment

More information

CMS-1345-NC2: Waiver Designs in Connection With the Medicare Shared Savings Program and the Innovation Center

CMS-1345-NC2: Waiver Designs in Connection With the Medicare Shared Savings Program and the Innovation Center Submitted Electronically Donald Berwick, M.D., M.P.P. Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services Room 445-G, Hubert H. Humphrey Building 200 Independence

More information

THE FRAUD PREVENTION SYSTEM IDENTIFIED MILLIONS IN MEDICARE SAVINGS, BUT THE DEPARTMENT COULD STRENGTHEN SAVINGS DATA

THE FRAUD PREVENTION SYSTEM IDENTIFIED MILLIONS IN MEDICARE SAVINGS, BUT THE DEPARTMENT COULD STRENGTHEN SAVINGS DATA Department of Health and Human Services OFFICE OF INSPECTOR GENERAL THE FRAUD PREVENTION SYSTEM IDENTIFIED MILLIONS IN MEDICARE SAVINGS, BUT THE DEPARTMENT COULD STRENGTHEN SAVINGS DATA BY IMPROVING ITS

More information

Medicare Fraud, Waste, and Abuse Training for Healthcare Professionals 2010-2011

Medicare Fraud, Waste, and Abuse Training for Healthcare Professionals 2010-2011 Medicare Fraud, Waste, and Abuse Training for Healthcare Professionals 2010-2011 Y0067_H2816_H6169_WEB_UAMC IA 11/22/2010 Last Updated: 11/22/2010 Medicare Requirements The Centers for Medicare and Medicaid

More information

CORPORATE COMPLIANCE POLICY AND PROCEDURE

CORPORATE COMPLIANCE POLICY AND PROCEDURE Title: Fraud Waste and Abuse Laws in Health Care Policy # 1011 Sponsor: Corporate Approved by: Carleen Dunne, Director, Corporate and Privacy Officer Issued: Page: 1 of 7 June 25, 2007 Last Reviewed/Updated

More information

Medicare Advantage and Part D Fraud, Waste, and Abuse Training. October 2010

Medicare Advantage and Part D Fraud, Waste, and Abuse Training. October 2010 Medicare Advantage and Part D Fraud, Waste, and Abuse Training October 2010 Introduction 2008: United States spent $2.3 trillion on health care. Federal fiscal year 2010: Medicare expected to cover an

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

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

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

PROGRAM INTEGRITY 101. Program Integrity Kimberly Sullivan, JD Medicaid Program Integrity Director

PROGRAM INTEGRITY 101. Program Integrity Kimberly Sullivan, JD Medicaid Program Integrity Director PROGRAM INTEGRITY 101 Program Integrity Kimberly Sullivan, JD Medicaid Program Integrity Director PURPOSE 2 Assure the Programmatic and Fiscal Integrity of the Louisiana Medical Assistance Program (Medicaid).

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

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

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

Compliance Training for Medicare Programs Version 1.0 2/22/2013

Compliance Training for Medicare Programs Version 1.0 2/22/2013 Compliance Training for Medicare Programs Version 1.0 2/22/2013 Independence Blue Cross is an independent licensee of the Blue Cross and Blue Shield Association. 1 The Compliance Program Setting standards

More information

PATIENT TRANSFER AGREEMENT BETWEEN AND

PATIENT TRANSFER AGREEMENT BETWEEN AND PATIENT TRANSFER AGREEMENT BETWEEN AND THIS PATIENT TRANSFER AGREEMENT ( Agreement ) dated ( Effective Date ) is entered into by and between ( ) and ( ). WITNESSETH WHEREAS, and share a mutual desire to

More information