AGENDA - Bay-Arenac Behavioral Healthbabha.org/wp-content/uploads/2016/09/July-5-2017-Health-Care... · 09.07.2016 · 3.2) Corporate Compliance Committee Notes from 3.2) M- S-MA

AGENDA

BAY ARENAC BEHAVIORAL HEALTHBOARD OF DIRECTORS

HEALTH CARE IMPROVEMENT & COMPLIANCE COMMITTEE MEETINGWednesday, July 5, 2017 at 5:00 pm

Behavioral Health Center, 201 Mulholland, Bay City, MI 48708

COMMITTEE MBRS: Present Excused Absent Present Excused Absent OTHERS PRESENT:R. Pawlak, Ch --- . P. McFarland -- --- BABHA: Chris Pinter and Sara BrandtJ. Andrus --- T. Starkweather -- ---R. Gromaski --- J. Anderson, Ex Off __ ---C. Maillette, V Ch ___ R. Byrne, Ex Off --T. Marta ---

AGENDA ITEM KEY DlSCUSSlON POINTS ACTION - MOTION - RESOLUTION

l. Roll Call

2. Public Input

Corl!orate Coml!liance Rel!ort 3.1)M- S- MA3.1) Compliance Update Received the report

3.3.2) Corporate Compliance Committee Notes from 3.2) M- S- MA

April 18,2017 Received the notes

Other Rel!orts

4. 4.1) Primary Network Operations & Quality 4.1) M- S- MAManagement Committee Meeting Notes from April Received the notes13,20l7

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AGENDA

BAY ARENAC BEHA VI ORAL HEALTHBOARD OF DIRECTORS

HEALTH CARE IMPROVEMENT & COMPLIANCE COMMITTEE MEETINGWednesday, July 5,2017 at 5:00 pm

Behavioral Health Center, 201 Mulholland, Bay City, MI 48708

5. Unfinished Business5.1)None

I

I

6. New Business6.1) Corporate Compliance Training Follow Up

7. Adjournment M- S- pm 'MA

Present AD HOC MEMBERS: Present

BAY-ARENAC BEHAVIORAL HEALTH

BABH CORPORATE COMPLIANCE COMMITTEE MEETING

Tuesday, April 18, 2017 (2:00 - 4:30)BABH - Room 335

MEMBERS: Present

Janis Pinter, Compliance & Privacy Officer, Chair X Becky Smith, Director of HR DirectQrs of Int~grated Health CareEllen Lesniak, Finance Manager, Vice Chair X Amy Folsom, Clinic Practice Manager X Karen Amon XJoelle Sporman, Recorder I IErin Lewis, Contract Admin. X IJoelin Hahn XBrett Kish, Security Officer I IBrenda Beck, Medical RecordsSandy Gettel, Quality Manager I X I Melissa Prusi, RR/CSManager X Guests: I none

# Topic Key Discussion Points Action Steps

1 Agenda: Review/Additions There were no additions to the agenda.Meeting Notes: Approval for The 03/21/17 meeting notes were approved as written.03/21/17

2 Data/Monitoring: a) Deferred until Brenda Beck is presentMonthly: b) Nothing new to report other than continuing to emphasize use of patienta) EHR Breach Monitoring portal to meet required targets.b) Meaningful Use Prescriber c) No findings to report this month.

Compliance d) Deferred until Brett Kish is present.c) Exclusion/Debarment e) Nothing new to reportd) Monitoring of Group Drives for

Unsecured PHI Filese) Reports of Issues of Significance

3 Open/Outstanding Items: a) Nothing new to report this month; waiting on review of final documents a) Finance/ Sandy to draft/revisea) Policy for Financial/Clinical from Mid-State. policies as needed.

Oversight of Fiscal b) Amy reported there are signs at the clinic offices reminding consumers to b) Ellen to verify scope of issueIntermediaries present their insurance cards and front desk staff have been educated; and report back; Janis to check I

b) Fraud/Abuse Risk Assessment Amy unsure what other action to take; consider adding a question to the with PCEregarding solutions in I

Action Plan - Coordination of sign-in sheet labels. Ellen to check the current scope of the problem since use by other CMHSP's; Amy addI

Benefits for Clinics the Risk Assessment is now a few years old. Janis reported the Risk question to clinic sign-in sheet? I

c) Provide feedback if any to Karen'

1

# Topic Key Discussion Points Action Steps- -

c) Personal Care Services in Assessment was due to be renewed soon; Janis to check with PCE d) Sandy to check with T. LewickiSpecialized Residential - Policy regarding how other CMHSP's address this problem. and report backRevision Status c) Members to review and provide feedback to Karen.

d) Home/Community Based Rules d) Work group in place; HCBSsurveys for people receiving B3 services areCompliance Status about to be sent out by the state or PIHP; discussed continuing concerns

e) PA 403 of 2016 - Licensure of about the state model for long term management of HBBS complianceApplied Behavior Analysts and potential over-reliance on a restricted access portal- the WSA; Sandy

f) PA 359 of 2016 - Disallows to follow up with T. Lewicki at the PIHP regarding status.Prescribing Controlled e) Joelin reviewed the law and noted grandfathering provisions wereSubstances Via Tele-Health; included for existing AnalystsCorrective Bill SB 213 f) New bill in the legislature to require a face-to-face evaluative contact with

g) Status of Gallery Breach the patient prior to starting telehealth; MACMHB is advocating for revisedMonitoring language.

g) Deferred until Brett Kish present.

4 Review of Plans, Policies,Procedures and Reportsa) None

5 State and Federal Policy: a) The Medicare Access and CHIP Reauthorization Act (MACRA), requires us c) Janis to request legal opiniona) Medicare - Social Security to remove social security numbers from all Medicare cards by April 2019.

Number Removal Initiative A new randomly generated Medicare Beneficiary Identifier (MBI) will(SSNRI) replace the social security number based Health Insurance Claim Number

b) 42 CFRPart 2 - Revisions to SUD on the new Medicare cards for Medicare transactions like billing,Confidentia litv eligibility status, and claim status.

c) PA 559 of 2016 - Revisions to b) Nothing new to reportMHC for Release of Information c) BABH requesting a legal opinion regarding the scope of the state standard

d) PA 359 of 2016 - Prescribing behavioral health consent and the MHC revisions regardingControlled Substances via Tele- confidentiality.Health d) Corrective bill adds a required face-to-face evaluation/assessment of the

e) Admin Law Judge Decision - patient by the prescriber; Board Association is advocating for languageApplied Behavioral Analysis changeServices 3rd Party Insurance e) to h) will be left on the agenda for discussion with the full committee

f) MSA 16-46 Coverage of TraumaServices

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2

# Topic Key Discussion Points Action Steps

g) MSA 17-01 CPT-HCPSCodeUpdates

h) MSA 17-08 Medicaid ManualQuarterly Update

6 Other/New Business: a) Suggested revisions to the Contract Checklist were briefly discussed; need a) When time permits, schedulea) Contract Checklist Suggested to set meeting to discuss at a later date. meeting to review potential

Revisions b) Members of the committee were informed there is a table available at the revisions to contract checklistb) Program/ Provider Use of following location for their reference which lists each provider and their

Phoenix Table degree of access to Phoenix as well as to what extent they are usingPhoenix for direct entry and scanning:G:\BABH\EHR Implementation \DirectProg-ContractProv _ UseOfPhoenix

7 Environmental Scan & Educational a) Nothing new to reportMaterials b) Defera) EDIT III Meetingsb) Status of QIDP-QMHP

Qualifications Changes

8 Adjournment/Next Meeting The next meeting is scheduled for Tuesday, 05/16/17 from 3:00-4:30 in Room335.

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3

BA~ ARENAC BAY-ARENACBEHAVIORAL HEALTHPRIMARY NETWORK OPERATIONS & QUALITY MANAGEMENT COMMITTEE MEETING

Thursday, April 13, 20171:30 p.m. - 3:30 p.m.

Mulholland - Conference Room 225

BEHAVIORAL HEALTH

M.EMlJElI$-- - - -

Present -- ~EMJER$ -Present MEMBJRS present'

- --BABH Primary Care Director: Joelin Hahn (Chair) X BABH BI/Corporate Compliance: Janis Pinter X MBPA CSM/SC Supervisor: Kathy Coleman

BABH Quality Improvement: Sandy Gettel (Chair) X BABH Nursing Team Leader: Sarah VanParis MPA Adult OPT Director: Katy Dean X

BABH/Arenac -Integrated Care Director: Karen Amon BABH Nursing: Heather Seegraves MPA Adult CSM/SC Supervisor: Matt Lance X

BABH Children Services: Noreen Kulhanek BABH Vocational Services: Brenda Rutkowski X MPA Children's OP Supervisor: Michelle Richards X

BABH Children Services: Stephanie Hoffman BABH PI Coordinator: Julayne Richmond X Saginaw Psych Barb Goss X

BABH IMH/HB: Kelli Maciag BABH Quality & Compliance: Sarah Holsinger X Saginaw Psych Nathalie MenendesBABH Clinic Manager: Amy Folsom X BABH Clinical Services: Heather Friebe Touchstone/Opportunity Center Jen Whyte

BABH ES/Access: Kristy Moore BABH RR/Customer Services: Janelle Steckley BABH Secretary: Joelle Sporman (Recorder) X

BABH ES/Access: Margaret Dixon BABH RR/Customer Services: Jeff Wells X X

BABH Access: Stacy Krasinski X LPSCOO: Jackie Thompson X BA8H M-tloc: NiemtiefsiBABH Adult ID/DD Manager: Melanie Corrion LPSClinical Director: Kim Kern BABH Finance Department: Ellen LesniakBABH ACT/Adult MI Manager: Kathy Palmer MBPA Clinical Director: Cindy Soto X BABH Contracts Admin.: Erin Lewis

BABH Medical Records: Brenda Beck MBPA Program Director: Sandra Garcia X BABH RR& CSManager: Melissa Prusi

GUESTS: Amanda Philipp (LPS)--- - - - -

Topic Key Dlscus$ion Points ActionSteps/Responsibility- -

1. Review of and Additions to Agenda The meeting was called to order at 1:30 pm.

Approval of Meeting Notes from There were additions to the agenda:02/09/17 Meeting - 3f. MEV Report

- 4d. LARA SUD provider- 4e. ASAM Training- 5b. Transfers between agencies and add-on services- 5c. GF Benefit Expansion

Meeting notes to be reviewed by the committee.2. Guest Presentation No guest is present.3. Mid-State Health Network (MSHN)/ a. There is a request for urgent action to please consider contacting the Chair and a. Share the 298 language

Michigan Department of Health & Vice Chair of the House DHHS Budget Committee this week. The House DHHS with others.Human Services (M_DHH_S)

---Subcommittee is expected to vote on their FY18 budget recommendations on

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BA~ ARENAC BAY-ARENAC BEHAVIORAL HEALTHPRIMARY NETWORK OPERATIONS & QUALITY MANAGEMENT COMMITTEE MEETING



BEHAVIORAL HEALTH

a. Section 298 Update April 19th• There is belief that the House will include the language that suggests a d. Joelle to schedule ab. MSHN Care Management/Care HMO Pilot in their 298 language. Health plans want to get language put in 298 to meeting with LPSand

Coordination allow for pilot projects. Please share this information with others. MBPA to discuss thec. Autism Review - May 23 b. Nothing to report this month. MSSV.d. Mid-State Supplementary c. The Autism review will be taking place at MSHN on May 23rd• The sample has

Values (MSSV) been received for the review and Sarah is working on making sure we have alle. Work Group Updates documentation in the EHR.f. MEV Report d. The MSSV document is an effort to define MSSV eligibility logic for the purposes

of discussion and refinement. Further dialogue is needed to explore howseverity or degree of functional impairments, psychiatric symptoms, and riskelements impact eligibility determination, as well as the presence of a substanceuse disorder. BABH has volunteered to be a leader on this so we can keepcontrol. BABH has to provide a series of data elements to MSHN so they can lookat the entire region and see who is being served under this Medicaid benefit andwhat kind of need they have, and look for consistency in terms of what servicespeople are getting, what their encounters are and what their needs look like.Each field requires a yes or no answer. Saginaw Psych and MPA are all set. LPSand MBPA need to do this yet. We need to figure out how to do this and optionsare a free standing form assessment in Phoenix or use the clinical assessment.BABH will schedule a meeting on site to discuss further how to handle this.

e. Joelin is on the Inpatient Work Group at MSHN. The purpose is to go thru all thestate regulations from doing the prescreens, to authorizations, to continue stayreviews, to discharge planning and to make sure all the CMH's are interpretingthe regulations the same.

Sandy, Brenda and Karen are on the Employment Works Work Group. Talkedabout what data they would like to collect and have the outcomes for this. Withthe IPS program starting, BABH can implement the data.

Opiate prescribing Work Group is prescribing benzos and stimulants.

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BEHAVIORAL HEALTH

The LOCUSWork Group is starting at the board. Updates to follow as given.f. MSHN completes a MEV audit twice a year. Results are in from the February

audit. Total results was 99.51% overall. Code is an allowable service code underthe contract (100%), beneficiary is eligible on the date of service (100%), servicesincluded in the beneficiary's authorization or treatment plan (100%),documentation of the service agrees to the claim date, time of service (97.23%),documentation of the service provided falls within the scope of the service code(99%), and amount billed does not exceed ... (100%) and modifier ... (100%).There were 867 claims that were reviewed and 5900 units. The next audit willtake place in August.

4. BABH Announcements a. The Walk-A-Mile is scheduled for May 10th in Lansing. The Opportunity Center c. Remove from agenda.a. Walk-A-Mile will be organizing the event for BABH this year. If anyone is interested in helpingb. Night in June out, contact Jen Whyte at the oc.c. American Health Care Act b. The Night in June is scheduled for June 22nd at the Pinconning Park. Judithd. LARA SUD Provider Wyzkiewicz will be organizing the event this year. Judith is seeking volunteerse. ASAM Training for the event, so if anyone is interested, they can contact her via email at

jwyzkiewicz @yahoo.com.c. Remove from agenda.d. FYI- The state is having two informational sessions about substance abuse

licensure. They have expanded services on the substance abuse side.e. FYI- Joelin sent out information regarding the ASAM training. This training is

not required.

BABH has hired a Clinical Manager for ACT and Adult MI, Kathy Palmer, and she willstart May i=.

5. Clinical Process - Issues/Discussion a. We need to know how the specialty mental health need is being reflected in the b. Joelin to schedule aa. Specialty MH Eligibility assessments for SPMI, SEDand lOOT vs. mild to moderate. When doing annual work group to discussb. Transfers between agencies evaluations, as a system, we are near capacity for outpatient therapy and case this more in detail.

and add-on services management services. We do not want to cut anyone out of services, but whatc. GF Benefit Expansion Joelin is asking, is if someone has been stable for a year, we need to look at c. Joelin will email more

stepping them down t_o_a Medicaid Health Plan to a mild and moderate benefit. information on the GF

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mailto:@yahoo.com.




BEHAVIORAL HEALTH

If we do not do this, we are losing availability for those new people who come in expansion. Joelin willand need that specialty level of care. Determine correct eligibility. Look over the talk to Finance.MSSV from Janis.

b. This came about when Stephanie Hoffman was working on a check list fortransfers and add-ons between agencies. Stephanie and Michelle were talkingabout a timeframe of 30 days for the authorization when adding on services toengage the individuals. If adding on psych services or case managementservices, it needs to be 45 days from the initial and make sure the end datematches the end date of the PCP. Initial authorization needs to be one year fromthe date of the PCP. Any transfers or add-on at initial authorization will be for 45days.

We need to get a workgroup together to figure other details out. BABH has workto do to incorporate for the providers not using the EHR.

c. We can once again expand the GF services to near that of the Medicaid coreservices for the remainder of the fiscal year. Joelin will email more informationon this.

6. Prescriber Update a. All sites should have information on how to access the patient portal in thea. Patient Portal Intake packets. We need to make every effort to get our consumers to access

the patient portal because we need 5% per prescriber case load. The Children'sTeam is doing very well, they are at 10%.

7. Corporate Compliance Updates/ Health care reporting only one service can be reported for a given time period.Discussion While there may be other staff present, the service reported is the one that isa. Same-Time Services Reporting primary as experienced by the consumer. While CMHSP's and/or providers may, for

internal financial purposes, track the time/cost of additional staff or services duringthe primary service, not all information is reported to the state. There are someexceptions to the general rule of reporting one service for a given time period. Theconsumer must be present and have at least 15 minutes of interaction with the case

I

manager/supports coordinator for the monitoring activity and the service being

--monitored to be reported at the same time.

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BEHAVIORAL HEALTH

8. Phoenix System Nothing to report this month.Updates/Discussion

9. Summary/Data Analysis - Follow- MMBPIS for FY17Q1Up to Data Analysis l. Indicator 1: Percentage of Persons who received a I2rescreen within 3 hours ofa. Reporting request - BABH demonstrated a 100% for children and a 100% for adults.

1. MMBPIS Indicator 2: Initial Assessment within 14 days - MI-Children demonstrated a2. HEDIS-Diabetes Screen 94.2%, MI-Adult demonstrated a 96.2% and DD-Children/Adults demonstrated a3. PCPwithin 15 days 100%. BABH demonstrated a 95.7% for the total of all populations. Indicator 3:4. Healthcare Coordination Start of Service within 14 days - MI-Children demonstrated a 96.4%, MI-Adult5. Crisis Planning demonstrated a 95.6% and DD-Children/Adults demonstrated a 100%. Indicator

4a: Follow-UI2 within 7 days of discharge from IP - BABH demonstrated a 100%for children and a 98.1% for adults. Indicator 10: Re-admission to Psych Unitwithin 30 days - BABH demonstrated a rate of 11.5% for children and a 9.8% foradults. Indicator 2 fell below standard. We are on corrective action for indicators2 and 3. New actions for indicator 4 were done last quarter.

2. Had discussion about putting together an informational letter, which wascompleted by Julayne. There were three interventions that were identified at theCMH and the PIHP levels that will be evaluated on an ongoing basis to determinethe effectiveness to increasing the number of consumers who complete adiabetes screening. Julayne will get the list quarterly, break it down by programs,send out to the managers and the team leaders, and they will then distribute totheir staff. Case holders will then discuss what this is about, get assistance forthe clients, etc. We are trying to roll this out to get an increase in the data.

3. PCPwithin 15 days for BABH-AII went down this quarter from 93% to 89%. 100%sample of all person centered plans (data is pulled from PCE) improved in FY17Q2from 86% to 90%. The column, 'no evidence of the PCPin the header', is notbeing used for documenting that the PCPwas received within the 15 days.

4. Healthcare Coordination for BABH-AII was at 89%.5. Crisis planning for BABH-AII was at 96%.




BEHAVIORAL HEALTH

10. Project Descriptions/Development/ a. Sandy handed out the Quality of Care form and instructions.Improvements b. Nothing to report this month.a. Quality of Care Formb. Follow-up to Hospitalization

11. Consumer/Stakeholder Feedback a. There's nothing to report on the consumer log this month. Jeff passed around a b.S. Joelin to have Staceya. Consumer Log handout of the Recipient Right's complaints for FY17-Ql & Q2. Complaints have Krasinski, the Accessb. Standing Committees, gone down since the start of FY17Q2. The number of complaints received may Team Leader, to

Councils, Program and not meet the number of allegations as some complaints contain more than one follow-up with JackieContract Provider Reporting allegation. The #1 allegation is 'services suited to condition'. Take a look at the on how to streamline1. Recovery Committee handout and if there are any issues please let RR/CS know. the process on2. Quality of Life b. 1. Recovery Committee - There was a great turnout from game night. The first making referrals.3. Child and Family narcan kit has been distributed and there are still some available. Reminders

Committee about the upcoming Walk-A-Mile and the ending period for the MHSIP/YSS4. Consumer Councils consumer satisfaction surveys. Went over the suicide surveillance for Bay andS. LPS Arenac Counties. Individuals presenting for suicidal ideations at the emergency6. MBPA department has increased, but those presenting with a suicide attempt has7. MPA decreased. There were 15 Bay County suicides, which was a 50% increase from8. Saginaw Psychological last year, and there were 4 Arenac County suicides.

2. Quality of life - Nothing to report this month.

3. Child and Family - Nothing to report this month.

4. Consumer Councils - Nothing to report this month.

S. LPS- List hired someone that can take Medicare but that process needs toslow down. List is not accepting referrals for primary Medicare. The AccessCenter uses CareNet to make referrals but List does not use this as the standardprocess for making referrals.

I

6. MBPA - Defer iL_ . ---- -- --- -- - - -

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BEHAVIORAL HEALTH

7. MPA - Skills Group is a new curriculum which will take place for 3 weeks. It'sabout managing your mental health recovery and how to be the best mentalhealth patient you can be. On the new BABH website, there is a link on thebottom ofthe support group page with a hot link to MPA's Skill's Trainingcalendar. This link is a good resource for all to check out.

8. Saginaw Psych - Hired a new person but lost the Psychiatrist, David Dunn.Hold for referrals for outpatient therapy and child.

12. Other/Additional Remind staff of available services: Just a reminder that BABH has services availableat the Opportunity Center, Chores-R-Us and Peer Connect 360. The utilization ofpeers throughout the years has gone down and the OC is a great resource for someof the consumers.

Peer Connect 360 - A person does not necessarily have to be receiving treatment inthe SUD services to get the Peer Recovery Coaching and Peer Support services. Ifsomeone has co-occurring issues, whether in recovery or in remission and they needa recovery coach, call the Access Center and get them set up.

University Clinic: Just a reminder that if you see messaging from Ian Brand or LaToyaColvin, they are BABH employees working at the University Clinic.

Washington Elementary School Family Health Initiative - In the process of draftingan application for a second year grant. More information to follow.

Stepping Up Initiative - BABH meets with the courts, Prosecutor's Office, ProbationOffice, Jail administration, Sheriff's Department every 6 weeks to talk about how tostreamline deficiencies. In the process of potentially looking at a critical incidentteam (1 week 40 hour training) for law enforcement (not ali), to recognize those withMH or SUD issues. Collaboration in identifying barriers to getting people in to thesystem.

Joelin and Karen are working on a new initiative, CIT.

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8A~ ARENAC

BEHAVIORAL HEALTH

BAY-ARENACBEHAVIORAL HEALTHPRIMARY NETWORK OPERATIONS & QUALITY MANAGEMENT COMMITTEE MEETING



13. Adjournment The meeting adjourned at 3:30 pm.

Next Meeting The next meeting will be on Thursday, June 8th, 2017 from 12:30-3:00 m:n atMulholland in Conference Room 225. If there are any additional items that need tobe covered at the next meeting, please contact Joelin Hahn or Sandy Gettel.

Bay-Arenac Behavioral Health 4

Program Integrity:Role of the Board of Directors

~ Review and approve the Corporate Compliance Plan

~ Set policies which ensure BABHoperates a corporate complianceprogram as required by federal and state regulations

~ Assist with setting strategic priorities for the corporate complianceprogram based upon organizational risk tolerance and thelegislative, regulatory enforcement and financial environment

~ Receive and review reports from the corporate complianceprogram

~ Provide policy-level guidance for organizational response tosignificant program integrity inquiries such as those from the Officeof Inspector Generals at the state and federal level


Program Integrity:Role of the Board of Directors

~ Provide resources for use by the Chief Executive Officer to ensurean adequate compliance program, such as:~ Engagement of qualified consultants and legal advisors;

~ Purchase of specialized training for personnel as needed; and

~ Subscription industry journals/newsletters

~ Provide support for the compliance program through maintaining:~ Awareness of federal requirements that Corporate Compliance Officers

must have direct access to the Board of Directors on compliance issuesas warranted

~ Sensitivity to state and federal enforcement expectations if employeesor contractors approach the Board regarding corporate compliancerelated personnel action or recommended contract action by the ChiefExecutive Officer

Submitting false statements or making misrepresentations of fact toobtain healthcare payment for which no right would otherwise exist

J What is Fraud? I

~ Billing for services not furnished, including falsifying recordso Example: Billing for an appointment that was cancelled

o Example: Back-dating documents or signatures

o Example: Unsigned or missing documentation for services billed

~ Billing services at a higher level than the service actuallyprovided or documented - i.eo, {up-coding'o Example: billing a service provided by a nurse under a physician code

~ Falsifying or misrepresenting provider certification, registrationor licensureo Example: Working under an expired certification, registration a



I What is Abuse? ;

Practices that either directly or indirectly, result in unnecessary coststo the Medicaid or Medicare programs

~ Improper billing practiceso Example: Rounding up to a hour of service when only 10 minutes occurred

o Example: Billing two services at the same time (with limited exceptions)

~ Billing a service already covered elsewhere

o Example: Providing services to people that are the financial responsibility of anotherhealthcare program or insurance (i.e., not coordinating benefits)

o Example: Not charging the consumer any required fees

~ Billing for services for which the consumer is not eligible or which arenot medically necessaryo Example: Over-stating a person's level of need so they can remain in service or on a caseloado Example: No documentation in the clinical record showing services were medically necessary

_ ....._--" ..------------- -------


Civil and Criminal Penalties~ Federal and state FalseClaims Acts establish liability for submitting

false or fraudulent claims to the government, including Medicaid andMedicare

".;\.,.\•~ Includes criminal and civil action by state and federal authorities

o Penalties range from $21,563 to $73,568 (in 2016) per violation.

o May include an assessment of up to three times the amount claimed for eachitem or service, or up to three times the amount of remuneration offered,paid, solicited, or received

o Individuals and organizations have liability for false claims if they knew orshould have known their claim was false or fraudulent

~ Deliberately ignoring inaccuracies in claims or recklessly disregardingthe truth does not void liability

See related BABH policy/procedure: C13-S02-T16 - False Claims Act

Documents

AGENDA - Bay-Arenac Behavioral Healthbabha.org/wp-content/uploads/2016/09/July-5-2017-Health-Care... · 09.07.2016 · 3.2) Corporate Compliance Committee Notes from 3.2) M- S-MA