Welcome General Compliance Training

 To inform you who to contact to ask questions  To let you know that you are responsible to disclose  To share with you that you have a safe and confidential place to disclose

 Promote a workplace culture of ethics and compliance  Increase understanding of:  State and Federal Healthcare Laws  Shasta County’s policies  Employee Responsibilities  Promote compliance with federal health care program requirements

The ABC’s—Education Requirements:  The Federal False Claims Act  Administrative remedies for false claims and statements  Any state laws pertaining to civil or criminal penalties for false claims and statements  The whistleblower protections under such laws

 Fraud includes obtaining a benefit through intentional misrepresentation or concealment of material facts  Waste includes incurring unnecessary costs as a result of deficient management, practices, or controls  Abuse includes excessively or improperly using government resources

 False Claims Act  Anti-Kickback Statute  Physician Self- Referral Statute: (Stark Law)  Exclusion Statute  Civil Monetary Penalties Law

Prohibits the submission of false or fraudulent claims to the Government

Know or should have known… US Government pursues criminal and civil penalties for providers who:  Have actual knowledge of fraud and abuse or  Should have known about it when it occurs

Deliberate Ignorance

 US Department of Health and Human Services Office of Inspector General (OIG)  Department of Justice (DOJ) /U.S. Attorneys  FBI  State Medicaid Fraud Control Units (MFCUs)  Centers for Medicare & Medicaid Services (CMS)  Postal Fraud Investigators  Inspector General TRICARE  Secret Service  IRS

Incentives to report fraud  Up to 30% of any False Claims Act Recovery  Whistleblower Protections

 Billing for services not actually provided  Upcoding and bill padding  Billing for services that were not medically necessary  Kickbacks  Billing Medicare/Medicaid for a service that has already been paid for by another party  Drug companies promoting a drug for a use for which it has not been approved  Billing in order to increase revenue instead of billing to reflect actual work performed

The AKS prohibits soliciting or receiving anything of value, e.g., "in-kind” kickbacks, bribes or rebates in return for:  Referring patients for Medicare covered services  Buying an item or service covered by Medicare

Fines Prison Time Time Program Exclusion

Limits physician referrals when you have a financial relationship with the entity

 Mandatory exclusions  Permissive exclusions Exclusion from Medicare and Medicaid

Three strikes and you’re out!

Civil Monetary Penalties Law Penalties range from $10,000 to $50,000 per violation

Prevent and Detect:  Inaccuracies  Violations  Quality of Care Issues  Training Needs

The Compliance Committee is established to advise the Compliance Officer and assist in the implementation of the Compliance Program.

 New employees  Annually for all MH employees  Contract Providers

Non-Retribution, Non-Retaliation Policy

The toll-free confidential compliance line is:

List of Excluded Individuals and Entities – LEIE

PROVIDE HIGH QUALITY CARE BE ALERT & DISCLOSE ASK QUESTIONS DOCUMENTATION

Stay Alert!

Reporting to the Compliance program Confidential Disclosure Line Compliance Officer

Micki Mills…… Justina Larson… Nathalie Kuhn… Monteca Zumalt Alyson Kohl……… Sue Gustafson… Rachel Freemon… Compliance Questions

Compliance Policies and Procedures can be located at

 Do you know who to contact to ask questions?  Do you understand your responsibility to disclose?  Do you know you have a safe and confidential place to disclose?