1. Deficit Reduction Act of 2005 Signed into law February 8, 2006.

2. Addresses deficit reductions ranging from education to housing and Medicare to Medicaid. Fraud and abuse enforcement is aimed at containing the rise in Medicaid spending. Requires employees to be educated about False Claims. Training will occur at hire and annually.

3. What is the False Claims Act?  Prohibits any person from knowingly presenting or causing to be presented, a false or fraudulent claim for payment or approval of government funds.

4. Penalties Any person who knowingly submits a false or fraudulent claim to a state Medicaid program is liable to the federal government for three times the amount of the federal government’s damages plus penalties of $5,000 to $11,000 per false or fraudulent claim. Any person who knowingly submits a false or fraudulent claim to a state Medicaid program is liable to the federal government for three times the amount of the federal government’s damages plus penalties of $5,000 to $11,000 per false or fraudulent claim.

5. Some Examples of Health Care Fraud Billing for services or goods not provided; Falsifying certificates of medical necessity and billing for services not medically necessary; Billing separately for services that should be a single service; Falsifying treatments plans to maximize payments

6. Other Examples Failing to report overpayments; Duplicate billing Misuse of provider ID numbers, which results in improper billing and payments. Making false statements. Participating in kickbacks. Improper entries on cost reports.

7. How should I report suspected fraud? The Bair Foundation through its Problem Resolution Procedures, Policy #718 of the Employee Handbook encourages employees to report and concerns through either the Informal or Formal Complaint Procedure. If you suspect fraud, submission of false medical billing claims or other non- compliance with federal, state, local laws, regulations or TBF policies please refer to the policy.

8. There will be no retaliation for reporting.  Policy #718 also states that retaliation against an employee for reporting a complaint or for participating in an investigation for a complaint is a serious violation of TBF policies.  Any acts of retaliation should be reported immediately and will be promptly investigated and addressed.

9. Discipline for making a false claim for payment.  Any employee of TBF who is found to be presenting or causing to be presented, a false or fraudulent claim for payment or approval of government funds will be subject to Policy #701 in the Employee Handbook.  The policy states that falsification of any work records is one reason a discharge may occur for a first offense.