Fraud and Corruption in the Health Insurance Industry
|
|
- Egbert Clark
- 5 years ago
- Views:
Transcription
1 Fraud and Corruption in the Health Insurance Industry Georgia Skorczyk Area Manager Human Resources and Legal Department of the Techniker Krankenkasse SAS Forum /23. May 2007 in Stockholm
2 Introducing the TK Basic Information as of Founded: Members / Insured Parties: CHI Market Share: Budget 2006: Employees: Volunteer TK-Advisors: National Premium Rate: TK risk adjustment payments (RSA): 27 October 1884 in Leipzig as the Registered Assistance Fund for German Architects, Engineers, and Technicians" 4 Million / 6.1 Million 7.9% Approx billion EUR in over 200 locations, including 509 trainees in businesses and colleges Contact people for social welfare matters 13.5 % (since ) Additional premium rates for employees: 0.9% (since ) 3.7 billion Euro (in 2005) 38.0 billion Euro (since 1994) 2
3 The reasons why all health systems are vulnerable to corruption Complexity of all health systems - large numbers of parties involved - complex relationships between medical suppliers, health care providers, policy makers & patients - high legal complexity Uncertainty in health markets - not knowing when and what illness will occur - not knowing who will fall ill and it what numbers - not knowing the effective treatment and its costs Imbalance of information - health professionals having information than patients Health Expenditures globally about 3 trillion a year And last but not least: health is not a normal commodity: It is extremely valuable. 3
4 Fraud and corruption in the health sector: an overview (I) Professional fraud and corruption - doctors claiming for patients they have not treated - doctors claiming for more treatments than they have actually done - doctors claiming for treatments which are not part of the benefit system Service Providers/Suppliers fraud and corruption - suppliers deliberately supplying second-hand goods, declaring them new - suppliers not passing on the discounts they receive to the health insurers - suppliers wrongly confirming entitlements to benefits - pharmacists billing wrong prices - pharmacists adding medicaments to the prescription or increase the prescribed quantity 4
5 Fraud and corruption in the health sector: an overview (II) Patient fraud and corruption - patients declaring they have lower salary in order to pay less for healthcare - patients creating multiple identities in order to receive numerous prescriptions to receive beauty articles instead of medication - patients giving away their health insurance card to people who are not entitled to healthcare by this health insurance Staff fraud and corruption - supporting patients, professionals and suppliers Criminal networks - stealing of prescriptions and health insurance cards Very special: Counterfeiting - endangering lives and generating costs - Estimated value: about 17 billion a year 5
6 CHI Regulatory framework Overview of Service Providers Contracted Dentists approx. 144 Billion Euro for Health Care Contracted Doctors Pharmacies Other Service Providers A choice of: approx orthopaedic technologist approx Optometrists approx Midwives approx Physiotherapists approx Emergency Service Workers Emergency Hospitals Source: - Bundesministerium für Gesundheit und Soziales (Statistik KV 45), Telemedizinführer Deutschland,
7 CHI Regulatory framework Service and Accounting Structure I Health Insurer Insurance Premiums Claimed expenses Invoicing Payment Service Provider Treatment Member/ Insured Party 7
8 CHI Regulatory framework Lack of Transparency and Potential for Abuse Core Problem: Lack of Transparency Lack of transparency in the German Health Care system a core problem This is responsible for: Above average costs Not reaching full performance potential, the German health care system only delivering average performance (Bertelsmannstudie 2001) Additionally hundreds of individual cases of fraudulent or corrupt practices have arisen unfortunately, the honest party (Doctor, Pharmacist, Physiotherapist) usually suffers. A thorough examination of the inefficiencies caused by a lack of transparency, poor leadership and fraud is not taking place. 8
9 Combating Insurance Abuse in the TK Investigation Group for Fraudulent Invoicing Directors Human Resources and Legal Department 197a- Position Investigative Group Clerical Staff General Administration Clerical Staff For fraud cases: - Investigations - Meetings of the Health Insurance Employees Association Legal Case Management Including filing charges on behalf of TK Data Analyst Fraud Detection Central Coordination 9
10 Combating Insurance Abuse in the TK Investigation Group for Fraudulent Invoicing Tasks of the Investigation Group Monitoring of internal and external indications of insurance abuse Processing and management of abuse cases Filing complaints/ reporting offences Establishing abuse identification grid through pattern analysis Cooperation with Federal prosecutors, criminal police and other health insurance companies. Representation of TK interests at the Federal level in all insurance abuse matters. 10
11 Combating Insurance Abuse in the TK Investigation Group for Fraudulent Invoicing Reasons for Investigation Monitoring System Abuse Identification Raster Advice from public prosecutors and police Investigation by investigative group Cooperation with other members of the Health Insurance Association and advice from other insurers. Advice from insured parties, public authorities, social welfare agencies, service providers and third parties. 11
12 Combating Insurance Abuse in the TK Investigation Group for Fraudulent Invoicing Notification Recording Inquiry Legal Processing Notification via advice from internal or external sources Data analysis according to investigative group identification raster Sorting according to regional jurisdiction. Prioritisation Entry into data bank Inspection of Case Request for accounts documentation Assessment of facts Breach of contract or fraud? Determine future action Filing of complaint, monitoring Damages ruling in or out of court Confirmation of initial position Damages assessment 12
13 Combatting Insurance Abuse in the TK TK Abuse Prevention Processes Verax List TK registers blocked cards in the software used by independently operating physicians and dentists (80% of practitioners), blocking up to three million cards and saving 50 million Euro. Abuse of stolen, found or illegally sold cards Incorrect premium exemptions 13
14 Combating Insurance Abuse in the TK Abuse Identification Raster TK Monitoring the Abuse Identification Raster Using data to stop known abuse and fraud practices Manipulated invoices, charging for higher value services (eg Optometrists) Patient transportation fraud Multiple invoicing Supply of unnecessary services (physiotherapy, midwifery and other service providers) Embezzlement of transferable discounts (dental laboratory, dentists) 14
15 Combating Insurance Abuse in the TK Abuse Identification Raster The TK Data Warehouse The uniform and consistent database for all data analysis TK- Insured Parties (anonymous) SAS Invoicing Doctors SAS Invoicing Hospitals SAS Invoicing Pharmacists SAS Invoicing Medication and Medical Aids SAS... SAS... SAS 15
16 Combating Insurance Abuse in the TK Abuse Identification Raster Using the TK Data Warehouse Doctors Health Insurance data TK Insurance Abuse Investigation Group Pharmacy Prescription Information TK Data Warehouse SAS Hospital Invoicing data other Service providers Invoicing- and Consultation data SAS- Enterprise Guide Case Data Bank Fraud Pattern Abuse Identification Raster Suspicious Invoices 16
17 Combating Insurance Abuse in the TK Abuse Identification Raster Abuse Identification Raster All invoices to be checked Non suspicious invoices Raster Analysis should identify all red invoices and a minimum of green invoices Suspicious invoices Individual checking 17
18 Combating Insurance Abuse in the TK Working Example Optical Aids The Case: Incidence: Optometrist charges for high value optical aids (multi-focal lenses) although single strength lenses or even sunglasses were delivered. Nation wide Damages: up to Status: Found through: Charges have been filed. Abuse Identification Raster analysis 18
19 Combating Insurance Abuse in the TK Working Example Dental Prosthesis from Abroad The Case: Dentists work with laboratories and order dental prostheses from abroad, but charge the highest German prices. Case Globudent: 423 cases against dentists. Further laboratories are being targeted. Incidence: Nation wide. Damages: in total 4.5 million Euro (Globudent) Future cases: not yet calculable Timeframe: 10/99 until 02/2003 Status: Globudent: Trial completed. Future cases: Charges have been filed. Trial underway. Found through: Media, Abuse Identification Grid analysis 19
20 Combating Insurance Abuse in the TK Working Example Stolen Health Insurance Cards The Case: Medications: Incidence: Damages: Status: Found through: Doctors and Pharmacists exploit false, stolen or found health insurance cards. Multiple prescriptions are taken to pharmacists and charged. Stomachic, pain relievers in inconspicuous amounts Hamburg Several hundred thousand Euro Charges have been filed. Routine checking (Statutory liability checking) 20
21 Combating Insurance Abuse in the TK Working Example Stolen blank original prescription forms in 2004: Dealing with stolen prescription forms from 25 Doctors. Included 1 doctor from Saxony and 1 doctor from BRB : Notification from pharmacist Charges filed by pharmacist/ Lodged in STA Braunschweig 3 doctors (including 1 from Dresden) 119 pharmacists : Notification from AOK Nationwide use of prescriptions : Notification from police 2 doctors and 32 pharmacists Trial started by TK Clear involvement of: Bayern Berlin and Berlin : Notification from police; Arrest of 2 suspects 1 doctors and 19 pharmacists Charges filed by TK : Notification from police 1 doctor and 1 pharmacist Charges filed by TK : Notification from TK 9 doctors (including 4 from Leipzig) ) and 31 pharmacists Charges filed by TK : Notification from TK 5 doctors and 26 pharmacists Charges filed by TK : Notification from TK; 1 Berlin doctor and 14 pharmacists, complaint filed by TK, Prescriptions from these doctors turned up in 9 other cases and were used in 8 further states (total 253 prescriptions from these doctors) : Notification from police 3 doctors and 28 pharmacists Charges filed by TK/ Trial commenced by STA Berlin : Notification from police 4 doctor and 34 pharmacists : Notification from police 2 doctors and 60 pharmacists : Notification from doctor 1 doctor and 1 pharmacist : Notification from police 3 doctors and 9 pharmacists from Saxony, One from Thuringia and 76 Berlin pharmacists : Notification from TK; 6 doctors and 42 pharmacists (9 Baden Wüttenburg, 1 Brandenburg, 13 Lower Saxony, 3 Saxony, 16 Berlin) : Notification from TK 1 doctor and 5 pharmacists; charges filed by TK : Notification from TK; 8 doctor and 29 pharmacists; charges filed by TK : Notification from TK; Bulletin to all dentists in Berlin; 6 pharmacists in Baden-Wüttenburg, 1 Brandenburg and 34 Berlin pharmacists 21
22 Future Prospects Creation of the electronic Health Insurance Card The electronic Key in the Patient s Hand: Memory Card Only a memory card, like a blackboard Can be read by any machine Data can be altered by anyone Processor Card Mini computer with own secure operating system Memory only accessible by authorised points (read, delete, change, conceal) Only for use by the authorised person Encrypted data Secured data The creation of the electronic Health Insurance Card (HIC) will replace all existing health insurance cards. 22
23 Future Prospects Creation of the electronic Health Insurance Card Security Features of the HIC Security Features of the HIC Passport Photo PIN Code Copyrighted 23
24 Our mission: We want to create an Anti-fraud and Anti-corruption culture among all participants of the health care system We want to deter by actively expose those who engage in fraud and corruption We want to use state of the art IT systems to detect fraud and corruption We want to use effective prevention systems so that when criminal activities are attempted they will fail We want to seek financial redress in order to get back the financial resources lost to criminal activities and to give them back to our clients We want to make the public aware of the great impact fraudulent activities have on the health sector 24
ANTI-FRAUD PLAN INTRODUCTION
ANTI-FRAUD PLAN INTRODUCTION We recognize the importance of preventing, detecting and investigating fraud, abuse and waste, and are committed to protecting and preserving the integrity and availability
More informationAmy Bingham, Compliance Director Reviewed Only Date: 6/05,1/31/2011, 1/24/2012 Supersedes and replaces: "CC-02 - Anti-
MOLINA HEALTHCARE Polic:y and Procedure No. C 08 of Utah Effective Date: November 2003 Reviewed and Revised Ollie: 2/6/08; 2/25/0S; 11 /5/0S; II/ IS/OS, 3/4/09, 6/9/09, S/31 / 1O Amy Bingham, Compliance
More informationCompliance and Fraud, Waste, and Abuse Awareness Training. First Tier, Downstream, and Related Entities
Compliance and Fraud, Waste, and Abuse Awareness Training First Tier, Downstream, and Related Entities 1 Course Outline Overview Purpose of training Effective Compliance program Definition of Fraud, Waste,
More informationOperational Policy General Treatment Provider Recognition
Purpose Health Partners ( the Fund ) pays benefits for treatment provided to its policy holders ( Members ) by Recognised Providers. To be recognised by Health Partners, Providers must meet the recognition
More informationThe Missouri SMP. Empowering Seniors to Prevent Healthcare Fraud
The Missouri SMP Empowering Seniors to Prevent Healthcare Fraud SMP s Department of Health and Human Services Administration for Community Living/Administration on Aging Mission of the Missouri SMP Empower
More informationWHISTLEBLOWER PROTECTION POLICY
WHISTLEBLOWER PROTECTION POLICY NOVEMBER 2016 Policy Whistleblower Protection Policy Approval Date 22 November 2016 Approved By R. Armstrong Owner Group Security, Fraud and Crisis Manager Version 0.1 Amendments
More informationDEFICIT REDUCTION ACT AND FALSE CLAIMS POLICY INFORMATION FOR All NEW YORK WORKFORCE MEMBERS
DEFICIT REDUCTION ACT AND FALSE CLAIMS POLICY INFORMATION FOR All NEW YORK WORKFORCE MEMBERS The Company is committed to preventing health care fraud, waste and abuse and complying with applicable state
More information2016 Business Associate Workforce Member HIPAA Training Handbook
2016 Business Associate Workforce Member HIPAA Training Handbook Using the Training Handbook The material in this handbook is designed to deliver required initial, and/or annual HIPAA training for all
More informationPolicy to Provide Information for Combating Fraud, Waste and Abuse and the Ability of Employees to Report Wrongdoing
1 of 8 and Abuse and the Ability of Employees to Report Wrongdoing 1. Purpose The purpose of this policy is to provide information for combating fraud, waste and abuse and the ability of employees to report
More informationAPPENDIX 2 CORPORATE ANTI-FRAUD AND CORRUPTION STRATEGY
APPENDIX 2 CORPORATE ANTI-FRAUD AND CORRUPTION STRATEGY January 2017 CONTENTS Section Page 1 Introduction 3 2 Definition of Fraud 3 3 Standards 4 4 Corporate Framework and Culture 4 5 Roles and Responsibilities
More informationB. The College is considered a "creditor" under the Red Flags Rule because it defers payment for services rendered.
COLLEGE of CENTRAL FLORIDA ADMINISTRATIVE PROCEDURE Title: Identity Theft Prevention Program Procedure Page 1 of 5 Implementing Procedure For Policy # # 2.04 Date Approved: 07/07/11 Division: Administration
More informationPROCEDURE. This procedure is intended to identify third party arrangements and red flags involving College activities that will:
Subject Source PROCEDURE Identity Theft Prevention Vice President, Finance and Administrative Services Number: 1.07.02 Reference (Rule #) 6HX14-1.07 President s Approval/Date: 12/21/2017 POLICY: PURPOSE:
More informationFraud Control Framework
London Pension Fund Authority Fraud Control Framework Dec 2017 Page 1 of 14 Introduction: From April 2016 the LPFA partnered with Lancashire County Pension Fund (LCPF) in order to establish Local Pensions
More informationANTI-FRAUD CODE CONTENTS INTRODUCTION GOAL CORPORATE REFERENCE FRAMEWORK CONCEPTUAL FRAMEWORK ACTION FRAMEWORK GOVERNANCE STRUCTURE
ANTI-FRAUD CODE CONTENTS INTRODUCTION GOAL CORPORATE REFERENCE FRAMEWORK CONCEPTUAL FRAMEWORK ACTION FRAMEWORK GOVERNANCE STRUCTURE PREVENTION, DETECTION, INVESTIGATION AND RESPONSE MECHANISMS APPLICATION
More informationAMENDED ANTI-FRAUD PLAN FOR AVMED, INC. Amended November 2014
AMENDED ANTI-FRAUD PLAN FOR AVMED, INC. Amended November 2014 AvMed, Inc. hereby amends the Anti-Fraud Plan of its Special Investigations Unit ("SIU") which was created to identify, investigate, and rectify
More informationIdentity Theft: Protecting, Monitoring and Resolving
Identity Theft: Protecting, Monitoring and Resolving Presented by: James J. Holtzman, CFP, CPA Personal Chief Financial Officer and Shareholder Legend Financial Advisors, Inc. James J. Holtzman, CFP, CPA
More informationANTI BRIBERY FRAUD AND CORRUPTION. RES-CG-003-V02 Anti Bribary, Fraud and Corruption If printed this document is uncontrolled
ANTI BRIBERY FRAUD AND CORRUPTION RES-CG-003-V02 Anti Bribary, Fraud and Corruption If printed this document is uncontrolled 1. Scope This policy applies to all employees of the company and to temporary
More informationCommitment to Compliance
Introduction Commitment to Compliance SelectHealth has a compliance oversight program which supports compliant behavior by its employees and any of its contracted business partners, including first -tier,
More informationSpecial Advisory Bulletin
Special Advisory Bulletin The Effect of Exclusion From Participation in Federal Health Care Programs September 1999 A. Introduction The Office of Inspector General (OIG) was established in the U.S. Department
More informationRegistry General September 2015
Registry General September 2015 1 Charities Compliance Officer Training Topics What is FATF? How FATF relates to charities Guidance Notes on the Charities (Anti-Money Laundering, Anti-Terrorist Financing
More informationFRAUD PREVENTION POLICY
Page 1 of 13 FRAUD PREVENTION POLICY POLICY NO: 0094 Page 2 of 13 TABLE OF CONTENT Page 3 of 13 AMENDMENT AND APPROVAL RECORD TITLE: FRAUD PREVENTION POLICY Policy Number 0094 Effective Date From date
More informationMinnesota State Colleges and Universities Identity Theft Prevention Program
Effective 3-18-09 Identity Theft Prevention Program 1 This is the Minnesota State Colleges and Universities Identity Theft Prevention Program, including more detailed guidelines. The initial Program was
More informationIncreasing pressure on PBMs to identify fraudulent providers
Increasing pressure on PBMs to identify fraudulent providers How PBMs can use data, analytics and advanced technology to reduce their risk In July 2017, the Justice Department arrested more than 400 people
More informationTitle: First Name(s): Surname: Date of Birth: Address: State: Postcode: Mobile: Home Phone: Work Phone:
Claim Form Email Address claims fch@fastcover.com.au Phone Number 1300 409 322 Fax Number 02 8883 7002 Postal Address Fast Cover Claims Locked Bag 2010 St Leonards NSW 1590 Claim Number Office use only
More informationAnti-fraud and Corruption Policy
Anti-fraud and Corruption Policy Responsible Division: Finances Validated by: Board (Executive Committee) Date of approval: 17/05/2017 Date of next review: May 2019 Language versions available: English
More informationWhistle-Blowing Policy
2017 Ithmaar Bank Human Resources Department Table of Contents Table of Contents 2 1.0- Statement of Purpose: 3 2.0- Responsibilities 3.0- Actions Constituting Fraud 3.1- Criminal / Unethical Conduct 3.2-
More informationPharmacare Programs Audit Guide September 1, 2017
Pharmacare Programs Audit Guide September 1, 2017 TABLE OF CONTENTS 1. Definitions 3 2. Pharmacare Prescription Audits 5 3. Types of Audits 5 4. Required 7 5. Pharmacare Prescription Audit Recovery Procedures
More informationLION RE:SOURCES UK LIMITED (the Company ) ANTI-BRIBERY AND CORRUPTION POLICY
LION RE:SOURCES UK LIMITED (the Company ) ANTI-BRIBERY AND CORRUPTION POLICY applicable to third parties acting on behalf of UK Publicis Groupe companies Our values and principles This Policy has been
More informationAnti-Money Laundering Awareness Training Insurance Industry-Hong Kong
Anti-Money Laundering Awareness Training Overview This program is intended to give individuals working in the Hong Kong Insurance Industry a basic knowledge of money laundering and terrorism financing,
More informationAnti - Fraud and Corruption Policy
Anti - Fraud and Corruption Policy This policy applies Trust Wide Document control page Policy number Name of policy Names of linked procedures Accountable Director Author with contact details Status (draft/
More informationHonest and ethical behaviour policy
Policy Take Ownership Honest and ethical behaviour policy Issue Date 27 June 2018 Policy Number 004 This version dated 27 June 2018 supersedes all earlier dated documents. Table of contents Section A Introduction
More informationFraud, Bribery and Corruption Control Policy
Fraud, Bribery and Corruption Control Policy 1. Introduction DuluxGroup acknowledges the need for directors, executives, employees and contractors to observe the highest ethical standards of corporate
More informationAnti-Bribery, Anti- Corruption Policy
Anti-Bribery, Anti- Corruption Policy Reviewed by: B Carroll (Global Head of Compliance, Safety and Quality) Date: 21 Sep 2017 Approved by: A McLean (CEO) Date: 27 Sep 2017 Commercial-in-Confidence. All
More informationLast Updated: 1 February 2018 To be reviewed: Annually
CARE International Policy on Fraud and Corruption Awareness, Prevention, Reporting and Response Sponsor: Secretary General/CEO Policy Owner: Deputy Secretary General, CARE International Effective Date:
More informationANTI-FRAUD, BRIBERY AND CORRUPTION POLICY AND STRATEGY THE VIEW TRUST
ANTI-FRAUD, BRIBERY AND CORRUPTION POLICY AND STRATEGY THE VIEW TRUST INTRODUCTION 1. Introduction 2. What are Fraud, Bribery and Corruption? 3. Purpose of this Document 4. Scope of this Document 5. Anti-Fraud,
More informationCharging, Coding and Billing Compliance
GWINNETT HEALTH SYSTEM CORPORATE COMPLIANCE Charging, Coding and Billing Compliance 9510-04-10 Original Date Review Dates Revision Dates 01/2007 05/2009, 09/2012 POLICY Gwinnett Health System, Inc. (GHS),
More informationCategory: BOARD POLICY ADMINISTRATIVE PARAMETERS
Category: BOARD POLICY ADMINISTRATIVE PARAMETERS Title: Theft, Fraud, Corruption, and Non-Compliant Activities Policy Reference Number: AB 630 1. POLICY OBJECTIVES Last Approved: February 22, 2017 Last
More informationTerms of recognition as an approved Physiotherapist, Osteopath or Chiropractor with AXA PPP healthcare
Terms of recognition as an approved Physiotherapist, Osteopath or Chiropractor with AXA PPP healthcare (Please see the glossary for definitions of text in bold) Rules & benefits of member memberships Our
More informationINTERSERVE PLC POLICY ON FRAUD
INTERSERVE PLC POLICY ON FRAUD Interserve Plc ( The Company ) is committed to the highest standards of personal and corporate behaviour. We will not tolerate any incidence of fraud committed by workers
More informationAddress: State: Postcode: Yes (If Yes, provide details) No
Claim Number: Office use only Email Address travelclaims@woolworthsinsurance.com.au Phone Number 1300 10 1234 Postal Address Woolworths Travel Insurance Claims Locked Bag 2010 St Leonards, NSW 1590 Important:
More informationDEFICIT REDUCTION ACT AND FALSE CLAIMS POLICY INFORMATION FOR All MASSACHUSETTS WORKFORCE MEMBERS
DEFICIT REDUCTION ACT AND FALSE CLAIMS POLICY INFORMATION FOR All MASSACHUSETTS WORKFORCE MEMBERS The Company is committed to preventing health care fraud, waste and abuse and complying with applicable
More informationANTI-FRAUD POLICY. Reference No: ANTIFP-251. Policy Type: Governance. Directorate Area: All Directorates. Policy Author / Champion: Maurice Atkinson
ANTI-FRAUD POLICY Reference No: ANTIFP-251 Policy Type: Directorate Area: Policy Author / Champion: Governance All Directorates Maurice Atkinson Date(s) Equality Screened: 21 July 2017 Date(s) Approved
More informationBSA Modernization Can Strengthen Law Enforcement and Ease Compliance
November 29, 2018 BSA Modernization Can Strengthen Law Enforcement and Ease Compliance On behalf of the more 52,000 community bank locations across the nation represented by ICBA, we thank Chairman Crapo,
More informationAnti-Fraud Policy Date: Version: Review Date:
Anti-Fraud Policy Date: July 2017 Version: 4.0 Review Date: July 2019 Policy Title Anti-Fraud Policy Policy Number: POL 022 Version 4.0 Policy Sponsor Policy Owner Committee Chief Executive Director of
More informationTEXAS WORKFORCE COMMISSION LETTER. ID/No: Regulatory Integrity Date: August 17, 2009
TEXAS WORKFORCE COMMISSION LETTER ID/No: Regulatory Integrity 04-09 Date: August 17, 2009 TO: FROM: Executive Director Deputy Executive Director Commission Executive Staff Department Heads LWDB Executive
More informationCorporate Anti-Fraud Team (CAFT) Progress Report: April June 2015
Corporate Anti-Fraud Team (CAFT) Progress Report: April June 2015 July 2015 Clair Green Assurance Assistant Director Introduction This report covers the period 1 st April 2015 30 th June 2015 and represents
More informationPersonal Lending Products
Personal Lending Products Terms and conditions Applies from 15th July 2017 Introduction The details of your credit facilities are set out in the agreement which comes with this booklet. The agreement
More informationICBC Account Access Methods Terms and Conditions
ICBC Account Access Methods Terms and Conditions Version 22 August 2018 These terms and conditions apply to any Facility Account(s) which incorporates these terms and conditions. 1. Access to Facilities
More informationELEMENTS FOR THE CONTROL OF PHARMACEUTICAL PRODUCTS CONTAINING NARCOTICS AND PSYCHOACTIVE SUBSTANCES
ELEMENTS FOR THE CONTROL OF PHARMACEUTICAL PRODUCTS CONTAINING NARCOTICS AND PSYCHOACTIVE SUBSTANCES 2003 ELEMENTS FOR THE CONTROL OF PHARMACEUTICAL PRODUCTS CONTAINING NARCOTICS AND PSYCHOACTIVE SUBSTANCES
More informationPATIENT TREATMENT AGREEMENT
PATIENT TREATMENT AGREEMENT I understand that this Agreement is essential to the trust & confidence necessary in a physician/patient relationship and that my physician undertakes treatment based on this
More informationMODERNIZING ANTI-MONEY LAUNDERING AND ANTI-TERRORIST FINANCING LAWS AND REGULATIONS. White Paper July
MODERNIZING ANTI-MONEY LAUNDERING AND ANTI-TERRORIST FINANCING LAWS AND REGULATIONS White Paper July 2018 www.icba.org TABLE OF CONTENTS Introduction...3 Modernization will produce more useful information
More informationChristopher Newport University. Policy: Red Flag Identity Theft Identification and Prevention Program Policy Number: 3030
Christopher Newport University Policy: Red Flag Identity Theft Identification and Prevention Program Policy Number: 3030 Executive Oversight: Executive Vice President Contact Office: Comptroller s Office
More informationTHE CORPORATION OF THE CITY OF WINDSOR POLICY
THE CORPORATION OF THE CITY OF WINDSOR POLICY Service Area: Office of the CAO Policy No.: Department: Chief Administrative Office Approval Date: April 20, 2015 Division: Approved By: M140-2015 Effective
More informationCOMBATING INSURANCE FRAUD TACKING FRAUD IN HEALTH, MOTOR UNDERWRITING AND APPLICATIONS
COMBATING INSURANCE FRAUD TACKING FRAUD IN HEALTH, MOTOR UNDERWRITING AND APPLICATIONS INTRODUCTION INSURANCE FRAUD ISN T GOING AWAY UK May 2014: Insurance fraud at record high, says ABI Italy Feb 2015:
More informationUniversity of Cincinnati FACTA Red Flag Identity Theft Prevention Program
FACTA Red Flag Identity Theft Prevention Program FACTA Red Flag Policy Program, page 1 of 6 Contents Overview 3 Definition of Terms 3 Covered Accounts..3 List of Red Flags 3 Suspicious Documents...4 Suspicious
More informationWhistle-blower Policy
ABSTRACT Outlines the conditions and obligations of Southern Cross Group Pty Ltd. s (SCG) management & employees making a protected disclosure. Whistle-blower Policy Version 1.0 DOCUMENT NUMBER: Revision
More informationFighting Fraud Locally
Fighting Fraud Locally Fighting Tenancy Fraud the Threat to Housing Providers John Baker 26 November, London The scale of the problem - Annual Fraud Indicator 2013 Identified fraud loss for public sector
More informationThis little Piggy likes questions! FAQ Guide
This little Piggy likes questions! FAQ Guide A guide to some of the most frequently asked questions related to health spending accounts and some additional tips smart folks should know. Table of Contents
More informationCompliance Program. Health First Health Plans Medicare Parts C & D Training
Compliance Program Health First Health Plans Medicare Parts C & D Training Compliance Training Objectives Meeting regulatory requirements Defining an effective compliance program Communicating the obligation
More informationEXECUTIVE SUMMARY. A systematic approach for combating enrollment fraud
EXECUTIVE SUMMARY A systematic approach for combating enrollment fraud OCTOBER 2017 Enrollment fraud is a serious and growing problem The proliferation of identity fraud and new ways of enrolling in health
More informationAnti-Kickback Statute and False Claims Act Enforcement
Anti-Kickback Statute and False Claims Act Enforcement Nicholas Gachassin, III, Esq. Gachassin Law Firm, LLC Nick3@gachassin.com Press Conference on Health Care Fraud and the Affordable Care Act May 13,
More information1/29/2011. Mark G. Bodner Bureau Chief Complex Civil Enforcement Bureau Medicaid Control Unit Office of the Attorney General
Mark G. Bodner Bureau Chief Complex Civil Enforcement Bureau Medicaid Control Unit Office of the Attorney General The enactment of the Medicare and Medicaid Anti-Fraud and Abuse Amendments of 1977 authorized
More informationApproval version. G l o b a l P o l i c y : F r a u d R e s p o n s e a n d W h i s t l e b l o w i n g P o l i c y. Board of Directors.
Approval version G l o b a l P o l i c y : Issuer Author Approved by Board of Directors Group Legal Department Board of Directors Issue date July 01 2013 Revision history Publication via n/a BCnet Limitations
More informationHead office: Siegfried-Wedells-Platz Hamburg Insurance terms for travel health insurance - Young Travel VB-KV 2013 (YT-Out)
Head office: Siegfried-Wedells-Platz 1 20354 Hamburg Insurance terms for travel health insurance - Young Travel VB-KV 2013 (YT-Out) Your insurance terms comprise three sections. Section I. contains an
More informationTHE CHILDREN'S MERCY HOSPITAL ADMINISTRATIVE POLICY
THE CHILDREN'S MERCY HOSPITAL ADMINISTRATIVE POLICY TITLE: Identity Theft Prevention Program EFFECTIVE: 11/08 REVISION DATE: REVIEWED WITH NO CHANGES: 12/13 RETIRED: PURPOSE: The Identity Theft Prevention
More informationFRAUD A MULTIFACETED PHENOMENON TYPES OF FRAUD PREVENTION AND PROTECTION
FRAUD A MULTIFACETED PHENOMENON TYPES OF FRAUD PREVENTION AND PROTECTION Vadym NESTERCHUK Chairman, Director, Optima-leasing /SIXT Oleksandr SHAPOVALOV Authorised Operation Officer Organised Crime Control
More informationPalomar Community College District Procedure AP 5900 PREVENTION OF IDENTITY THEFT IN STUDENT FINANCIAL TRANSACTIONS
1 STUDENT SERVICES 2 3 AP 5900 PREVENTION OF IDENTITY THEFT IN STUDENT FINANCIAL TRANSACTIONS 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 References: Fair
More informationCORPORATE COMPLIANCE PROGRAM AND ENHANCED COMPLIANCE OBLIGATIONS
I. CORPORATE COMPLIANCE PROGRAM 1. A clearly articulated corporate policy against violations of the FCPA, including its anti-bribery, books and records, and internal controls provisions, and other applicable
More informationANTI-FACILITATION OF TAX EVASION POLICY
Issue 1 Page 1 ANTI-FACILITATION OF TAX EVASION POLICY This policy is endorsed by Harworth s Board of Directors and will be reviewed regularly. This policy may be changed from time to time and you will
More informationPharmacy Compliance- Credentialing, HIPAA and Fraud, Waste and Abuse (FWA) ACPE# L04-P ACPE# L04-T
Pharmacy Compliance- Credentialing, HIPAA and Fraud, Waste and Abuse (FWA) ACPE# 0761-9999-16-075-L04-P ACPE# 0761-9999-16-075-L04-T Credentialing and Other Terms the Pharmacy Should Know What are all
More informationThe Australian National University Fraud Control Framework. Corporate Governance & Risk Office
The Australian National University Fraud Control Framework 2017 2018 Corporate Governance & Risk Office Corporate Governance and Risk Office 21 July 2017 The Australian National University Canberra ACT
More informationYour Executive Health Plan
Your Executive Health Plan Administered by WellSpent, A Division of Wellknit Services Inc. This plan was arranged through: Your Executive Health Plan 2 Your Executive Health Plan allows you to purchase
More informationMedical Identity Theft Prevention Policy
SUBJECT: NUMBER: EFFECTIVE DATE: SUPERSEDES SPP: APPROVED BY: DISTRIBUTION: Medical Identity Theft Prevention Policy (signature) DATED: I. STATEMENT OF PURPOSE: To define medical identity theft and outline
More informationBenefit & General Conditions
Benefit & General Conditions www.whadirect.co.uk 1. THE FINANCIAL CONDUCT AUTHORITY (FCA) The FCA is the independent watchdog that regulates financial services. Use this information to decide if our services
More informationJune 2017 Whistleblower Policy
June 2017 Public POLICY CONTROL Effective from: 28 June 2017 Contact officer: Manager Organisational Development Last review date: Feb 2016 Next review date: N/A Published externally: Yes Status: Approved
More informationMedicare Parts C & D Fraud, Waste, and Abuse Training and General Compliance Training. Developed by the Centers for Medicare & Medicaid Services
Medicare Parts C & D Fraud, Waste, and Abuse Training and General Compliance Training Developed by the Centers for Medicare & Medicaid Services Important Notice This training module consists of two parts:
More informationSecond Level Student Account. Terms and conditions
Second Level Student Account Terms and conditions May 2018 Second Level Student Account application form and Terms and Conditions Contents Terms and Conditions - Second Level Student Account 2 Second Level
More informationANTI FRAUD, BRIBERY AND CORRUPTION POLICY
ANTI FRAUD, BRIBERY AND CORRUPTION POLICY St Alban Catholic Academies Trust Anti-Fraud, Bribery and Corruption Policy 1. Introduction The Scheme of Delegation and/or the Financial Regulations Handbook
More informationAnti-Bribery and Sanctions June 2011
Anti-Bribery and Sanctions June 2011 The UK Bribery Act The UK Bribery Act 2010 ("Bribery Act") comes into force on 1 July 2011. While this act is, in certain ways, similar to the US Foreign Corrupt Practices
More informationMEDICARE PRESCRIPTION DRUG PART D COMPLIANCE CONFERENCE. Reporting Requirements: Audit Preparedness for PDPs and Manufacturers
MEDICARE PRESCRIPTION DRUG PART D COMPLIANCE CONFERENCE Reporting Requirements: Audit Preparedness for PDPs and Manufacturers Polaris Management Partners 8:30 9:30am Concurrent Breakout Session AGENDA
More information21 - Pharmacy Services
21 - Pharmacy Services The role of Health Plan of Nevada s (HPN) Pharmacy Services is to evaluate and determine the appropriateness of quality drug therapy while maintaining and improving therapeutic outcomes.
More informationIdentity Theft Prevention Program
Slide 1 Identity Theft Prevention Program Welcome to the Identity Theft Prevention Program annual training course. Your personal identification information can be used by individuals seeking to use your
More informationRecognize it. Report it. Protect yourself.
Recognize it. Report it. Protect yourself. Insurance fraud in North Carolina is big business; in fact, sadly, it is a growing enterprise that costs each of us dearly. With approximately 10 percent of
More informationNATIONAL FRAUD CONTROL
2009 KAISER PERMANENTE NATIONAL FRAUD CONTROL UPDATE Over $2.2 trillion is spent on health care in the United States each year. The United States spends more than a $1,000 per capita per year 1 or close
More informationPOLICY: FRAUD PREVENTION. October 2017
POLICY: October 2017 CONTENTS 1. PURPOSE P3 2. SCOPE P3 3. LEGISLATION AND CORPORATE GOVERNANCE REQUIREMENTS REFERENCE 4. POLICY STATEMENT AND INTERNAL STANDARDS P3 P4 4.1 Background P4 4.2 Actions constituting
More informationPolicy 42 Anti-Fraud, Anti-Theft & Anti-Corruption
Policy 42 Anti-Fraud, Anti-Theft & Anti-Corruption Table of Contents Introduction...1 Our written rules...2 Expected Behaviour...2 Preventing fraud, theft and corruption...3 Detecting and investigating
More informationBusiness ATM/Debit Terms and conditions
Business ATM/Debit Terms and conditions Terms and Conditions Business ATM Card and Visa Business Debit Card 1.0 Definitions 1.1 Account means the business current account in respect of which the Card
More informationTitle Given name/s Surname Date of birth. Postal address Suburb State Postcode
Claim Form Submit your claim to CoverMore by: Post: CoverMore Claims Department Private Bag 913, North Sydney NSW 2059 Fax: 02 9202 8098 Email: claims_processing@covermore.com.au Phone: 1300 72 88 22 Part
More informationSaskatchewan Ministry of the Economy
Saskatchewan Ministry of the Economy June 2014 SASKATCHEWAN WAGE SURVEY 2013 - HEALTH CARE AND SOCIAL ASSISTANCE INDUSTRY DETALED REPORT SASKATCHEWAN WAGE SURVEY 2013: HEALTH CARE AND SOCIAL ASSISTANCE
More informationTo avoid delays in processing of your claim form, complete each section attaching documentation below when it applies.
CONTINENTAL AMERICAN INSURANCE COMPANY Post Office Box 84075 * Columbus, GA. 31993 Phone (800) 433-3036 * Fax (866) 849-2970 HOSPITAL INDEMNITY CLAIM FORM INSTRUCTIONS To avoid delays in processing of
More informationANTI-BRIBERY & CORRUPTION POLICY
1 INTRODUCTION 1.1 The Board of Directors of Ascendant Resources Inc. 1 has determined that, on the recommendation of the Corporate Governance Committee, Ascendant should formalise its policy on compliance
More informationGUIDANCE NOTE ON DETERING, PREVENTING, DETECTING, REPORTING AND REMEDYING INSURANCE FRAUD
GUERNSEY FINANCIAL SERVICES COMMISSION GUIDANCE NOTE ON DETERING, PREVENTING, DETECTING, REPORTING AND REMEDYING INSURANCE FRAUD Introduction Fraud is a serious risk to the insurance sector and can have
More informationGoCardless Merchant Agreement
GoCardless Merchant Agreement This Agreement was updated on 11 December 2018. If you signed up on or after 11 December 2018, you will be bound by this version of the Agreement. If you signed up before
More informationANTI-FRAUD, BRIBERY AND CORRUPTION POLICY
ANTI-FRAUD, BRIBERY AND CORRUPTION POLICY Version: 6 Date issued: February 2018 Review date: February 2021 Applies to: All Trust staff, contractors and vendors This document is available in other formats,
More informationSecure Information Destruction; A Legal Imperative
In this Issue Information as a Double-Edged Sword Not Knowing the Law Secure Information Destruction and Legal Compliance Information Security Recommendations From Shred-it Secure Information Destruction;
More informationTempleton Municipal Light and Water Plant
Templeton Municipal Light and Water Plant RED FLAG POLICY 1. POLICY It is the policy of the Templeton Municipal Light and Water Plant (TMLWP) that information compiled on all customers and employees is
More informationAnti-fraud and Corruption Policy
Contents Introduction... 2 Policy Statement scope and responsibilities... 2 Breaching the Policy... 3 What is Fraud?... 4 What are Bribery and/or Corruption?... 5 Guiding Principles... 5 Steps to prevent
More informationYMCA SOUTH AUSTRALIA Privacy Policy
Policy Title: Author: YMCA SOUTH AUSTRALIA Created by: 1 P a g e Policy Title: Author: 1. Introduction considers the privacy of individuals, staff, volunteers, clients, Member Associations and associated
More informationPREVENTING FRAUD IN THE HOSPITALITY INDUSTRY
PREVENTING FRAUD IN THE HOSPITALITY INDUSTRY Provided by David M. Bleser of Hospitality Safeguards, Inc. Jim Stover of Arthur J. Gallagher TABLE OF CONTENTS I. INTRODUCTION TO FRAUD...2 A. FRAUD FOUNDATION...2
More informationWhat s New for Stage 1 in 2014
The problem Your Accounting for a New Economy What s New for Stage 1 in 2014 Medical identity is now the fastest-growing type of identity theft in the world and Texas has become the fourth highest identity
More information