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Welcome
SHASTA COUNTY HEALTH AND HUMAN SERVICES
AGENCY
General Compliance Training
Our Goals Today
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
Purpose of the Training
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
Deficit Reduction Act - DRA
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
Health care fraud is a serious problem…
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
Fraud and Abuse Laws
False Claims Act
Anti-Kickback Statute
Physician Self-Referral Statute: (Stark Law)
Exclusion Statute
Civil Monetary Penalties Law
False Claims Act
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
Who Monitors Fraud & Abuse?
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
Examples of Fraudulent Activities:
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
Anti-Kickback Statute
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
FinesPrison Time
Program Exclusion
Penalties for Kickbacks
Physician Self-Referral Statute(Stark Law)
Limits physician referrals when you have a financial relationship with the entity
Mandatory exclusions
Permissive exclusions
Exclusion from Medicare and Medicaid
Balanced Budget Act (BBA)
Three strikes and you’re out!
Civil Monetary Penalties Law
Penalties range from $10,000 to $50,000
per violation
COME-PLY WITH US!
Compliance Program
Prevent and Detect:
Inaccuracies Violations Quality of Care
Issues Training Needs
Shasta County Mental Health, Alcohol & Drug Micki Mills, MA
Acting Compliance Officer
Compliance Committee
The Compliance Committee is established to advise the Compliance Officer and assist in the implementation of the Compliance Program.
Compliance Training
New employees Annually for all MH
employees Contract Providers
Disclosure Program
Non-Retribution, Non-Retaliation Policy
Disclosure The toll-free confidential compliance line is:
1 -866-229-8050
Whistleblower Protections
www.whistleblowers.gov/
Ineligible Persons Screening
List of Excluded Individuals and Entities – LEIE
Shasta County Mental Health, Alcohol and Drug
Code of Conduct
LAWS AND REGULATIONS
ETHICSQUALITY OF CARE
ACCURATE BILLINGRESPONSIBILITES
Employee Roles and Responsibilities
PROVIDE HIGH QUALITY CARE
BE ALERT & DISCLOSE
ASK QUESTIONS
DOCUMENTATION
CODE OF CONDUCT – FAILURE TO COMPLY
Shasta County Confidentiality Policy
CONFIDENTIALITY
IS KEY
Shasta County Confidentiality Policy
T M I
Stay Alert!
Reporting to the Compliance program
Confidential Disclosure Line1-866-229-8050
Compliance Officer245-6750
Micki Mills…….....225-5075Justina Larson….229-8266Nathalie Kuhn…..225-5185Monteca Zumalt.229-8159Alyson Kohl………245-6476Sue Gustafson….225-5117Rachel Freemon…..245-6429
Compliance Questions
Compliance Policies and Procedures can be located at
http://intranet/hhsa/index/Compliance.asx
Did we accomplish our Goals?
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?
