1. Welcome General Compliance Training

2.  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

3.  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

4. 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

6.  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

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

8. Prohibits the submission of false or fraudulent claims to the Government

9. 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

10. Deliberate Ignorance

11.  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

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

13.  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

14. 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

15. Fines Prison Time Time Program Exclusion

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

17.  Mandatory exclusions  Permissive exclusions Exclusion from Medicare and Medicaid

18. Three strikes and you’re out!

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

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

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

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

25. Non-Retribution, Non-Retaliation Policy

26. The toll-free confidential compliance line is: 1 -866-229-8050

27. www.whistleblowers.gov/

28. List of Excluded Individuals and Entities – LEIE

30. PROVIDE HIGH QUALITY CARE BE ALERT & DISCLOSE ASK QUESTIONS DOCUMENTATION

35. Stay Alert!

36. Reporting to the Compliance program Confidential Disclosure Line 1-866-229-8050 Compliance Officer 245-6750 Email mhcompofcr@co.shasta.ca.us

37. Micki Mills…….....225-5075 Justina Larson….229-8266 Nathalie Kuhn…..225-5185 Monteca Zumalt.229-8159 Alyson Kohl………245-6476 Sue Gustafson….225-5117 Rachel Freemon…..245-6429 Compliance Questions

38. Compliance Policies and Procedures can be located at http://intranet/hhsa/index/Compliance.asx

39.  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?