Montefiore Medical Center Compliance Program. Welcome House Staff Orientation

Size: px
Start display at page:

Download "Montefiore Medical Center Compliance Program. Welcome House Staff Orientation"

Transcription

1 Montefiore Medical Center Compliance Program Welcome House Staff Orientation

2 The Healthcare Industry Government is largest payor. Perception that $100 Billion Dollars per year lost because of on healthcare fraud and abuse. Also perception that medicine is not practiced safely in all instances and that conflicts of interest abound. Increasing resources devoted to audits and investigations at all levels of government and in private industry. Media and the public is supportive of these enforcement efforts.

3 Who Regulates Hospitals?

4 LAW PROHIBITS PENALTY Anti-Kickback (SSA 1128B) kickback, bribe or rebate directly or indirectly in return for referring a person Exclusion; fines; jail False Claims Act (31 USC 3729) false or fraudulent claims for payment actual knowledge; deliberate ignorance or reckless disregard of truth or falsity qui tam Damages civil penalties up to $11,500 per claim Physician Self- Referral Prohibition ( Stark ) (SSA 1877) Prohibits physicians from ordering designated health services for patients from entities with which the physician or an immediate family member has a financial interest Civil penalty of $15,000 for each bill & $100,00 for each scheme

5 Other Laws False Statements EMTALA OSHA Civil Rights HIPAA

6 MMC s Compliance Program Establishes a culture that promotes integrity and ethical behavior consistent with our mission. Provides assistance in complying with complex governmental regulations. Identifies issues of concern and detects and prevents patterns of improper conduct from developing and occurring.

7 Hotline Usage MMC s hotline is available to address concerns relative to noncompliance that can not be addressed through other channels 24 Hour Hotline MMC-8595 Labor and Employment issues should be addressed through your department or by contacting Human Resources at

8 Rights and Responsibilities All associates have a duty to report any suspected violations of the Code of Conduct. Anyone who reports conduct that he or she sincerely believes is improper will be protected from retaliation The Federal False Claims Act includes qui tam or whistleblower provisions that allow private persons (a.k.a whistleblowers or relators ) to sue on behalf of the United States If the qui tam action succeeds, the whistleblower is entitled to receive a percentage of the settlement, penalty or fine collected Whistleblowers are also granted protection under the law from discriminatory actions taken by employers MMC strongly encourages associates to report compliance concerns to the Compliance Department and to allow reasonable time for investigation of the concerns before contacting a government agency

9 What is a Conflict of Interest? A personal interest which could inappropriately influence business judgments Not always financial May be actual or perceived May be dependent on position May not be negative, but disclosure and management are key

10 How Are Conflicts Managed? Avoiding situations that create conflicts Decision-maker should not have conflict and should make decisions fairly and in accordance with policy (RFP s, due diligence) Use judgment to avoid or alleviate conflict or appearance of conflict Disclosure May fulfill responsibility Allows assessment of conflict, potential bias

11 Vendor Relationships New policy to be rolled out limiting pharma /device /dme vendors activities. No vendor sponsored lunches; no gifts of any kind. Only approved reps allowed on site. Vendors should not be detailing or soliciting business from Residents.

12 Compliance Office Contacts Lynn Stansel, Vice President & Counsel, Compliance (718) Laurie Radler, Director of Compliance & Information Privacy Officer (718) Mark Goodman, Manager Corporate Compliance (718) Maria Matzoros, Associate Vice President, Billing Compliance (718) Michelle Miller, Associate Director, Billing Compliance (718)

Current Status: Active PolicyStat ID: Fraud, Waste and Abuse

Current Status: Active PolicyStat ID: Fraud, Waste and Abuse Current Status: Active PolicyStat ID: 2397820 Policy Scope: Date Of Origin: 06/2015 Last Approved: 07/2016 Last Revised: 07/2016 Next Review: 07/2018 Sponsor: Policy Area: Regulatory Tags: Applicability:

More information

This policy applies to all employees, including management, contractors, and agents. For purpose of this policy, a contractor or agent is defined as:

This policy applies to all employees, including management, contractors, and agents. For purpose of this policy, a contractor or agent is defined as: Policy and Procedure: Corporate Compliance Topic: Purpose: Choice of NY is committed to prompt, complete, and accurate billing of all services provided to individuals. Choice of NY and its employees, contractors,

More information

What is a Compliance Program?

What is a Compliance Program? Course Objectives Learn about the most important elements of the compliance program; Increase awareness and effectiveness of our compliance program; Learn about the important laws and what the government

More information

Corporate Compliance Topic: False Claims Act and Whistleblower Provisions

Corporate Compliance Topic: False Claims Act and Whistleblower Provisions Purpose: INDEPENDENT LIVING, Inc. (also referred to as ILI, ) is committed to prompt, complete and accurate billing of all services provided to individuals. ILI and its employees, contractors and agents

More information

NewYork-Presbyterian Hospital Sites: All Centers Hospital Policy and Procedure Manual Number: D160 Page 1 of 8

NewYork-Presbyterian Hospital Sites: All Centers Hospital Policy and Procedure Manual Number: D160 Page 1 of 8 Page 1 of 8 TITLE: FEDERAL DEFICIT REDUCTION ACT OF 2005 FRAUD AND ABUSE PROVISIONS POLICY: NewYork- Presbyterian Hospital (NYP or the Hospital) is committed to preventing and detecting any fraud, waste,

More information

Self Funded Provider Manual. Self Funded Provider Manual 1. Section 8: Compliance

Self Funded Provider Manual. Self Funded Provider Manual 1. Section 8: Compliance Self Funded Provider Manual Section 8 Compliance Self Funded Provider Manual 1 Table of Contents 8 SECTION 8: COMPLIANCE... 3 8.1 COMPLIANCE WITH LAW... 3 8.2 KAISER PERMANENTE PRINCIPLES OF RESPONSIBILITY

More information

Cardinal McCloskey Community Services. Corporate Compliance. False Claims Act and Whistleblower Provisions

Cardinal McCloskey Community Services. Corporate Compliance. False Claims Act and Whistleblower Provisions Cardinal McCloskey Community Services Corporate Compliance False Claims Act and Whistleblower Provisions Purpose: Cardinal McCloskey Community Services is committed to prompt, complete and accurate billing

More information

FRAUD, WASTE, & ABUSE (FWA) for Brokers. revised 10/17

FRAUD, WASTE, & ABUSE (FWA) for Brokers. revised 10/17 FRAUD, WASTE, & ABUSE (FWA) for Brokers revised 10/17 OBJECTIVES After reviewing this information, you will be able to: Understand Fraud, Waste, and Abuse (FWA) training requirements; Be familiar with

More information

Ridgecrest Regional Hospital Compliance Manual

Ridgecrest Regional Hospital Compliance Manual Printed copies are for reference only. Please refer to the electronic copy for the latest version. REVIEWED DATE: 06/02/2014 REVISED DATE: 07/02/2013 EFFECTIVE DATE: 10/17/2007 DOCUMENT OWNER: APPROVER(S):

More information

Federal and State False Claims Act Education Policy

Federal and State False Claims Act Education Policy *TEAMHealth Policies and Procedures Policy Name: Federal and State False Claims Act Education Policy Effective Date: January 1, 2017 Approved By: Executive Compliance Committee Replaces Policy Dated: January

More information

CORPORATE COMPLIANCE POLICY AND PROCEDURE

CORPORATE COMPLIANCE POLICY AND PROCEDURE Title: Fraud Waste and Abuse Laws in Health Care Policy # 1011 Sponsor: Corporate Compliance Approved by: Russell J. Matuszak, Interim Director, Corporate Compliance and Chief Privacy Officer Issued: Page:

More information

AGENCY POLICY. IDENTIFICATION NUMBER: CCD001 DATE APPROVED: Nov 1, 2017 POLICY NAME: False Claims & Whistleblower SUPERSEDES: May 18, 2009

AGENCY POLICY. IDENTIFICATION NUMBER: CCD001 DATE APPROVED: Nov 1, 2017 POLICY NAME: False Claims & Whistleblower SUPERSEDES: May 18, 2009 IDENTIFICATION NUMBER: CCD001 DATE APPROVED: Nov 1, 2017 POLICY NAME: False Claims & Whistleblower SUPERSEDES: May 18, 2009 Provisions OWNER S DEPARTMENT: Compliance APPLICABILITY: All Agency Programs

More information

OHC CORPORATE COMPLIANCE PROGRAM (ACF & ECF) DOING THE RIGHT THING

OHC CORPORATE COMPLIANCE PROGRAM (ACF & ECF) DOING THE RIGHT THING OHC CORPORATE COMPLIANCE PROGRAM (ACF & ECF) DOING THE RIGHT THING Renee Olmsted, RHIA - Director Corporate Compliance, Risk Management, Privacy Officer Dan Vick, MD VP, Medical Affairs and Chief Medical

More information

Certifying Employee Training Navicent Health s Corporate Integrity Agreement Year Two

Certifying Employee Training Navicent Health s Corporate Integrity Agreement Year Two Certifying Employee Training Navicent Health s Corporate Integrity Agreement Year Two Corporate Integrity Agreement Effective 4/23/2015 Term of five years Basic Requirement: Maintain a Compliance Program

More information

Corporate Compliance Program. Intended Audience: All SEH Associates 2016 Content Expert: Lisa Frey -

Corporate Compliance Program. Intended Audience: All SEH Associates 2016 Content Expert: Lisa Frey - Corporate Compliance Program Intended Audience: All SEH Associates 2016 Content Expert: Lisa Frey - lisa.frey@stelizabeth.com Developed 2012, reviewed Dec 2015 What is Corporate Compliance? Hospitals,

More information

FEDERAL DEFICIT REDUCTION ACT POLICY

FEDERAL DEFICIT REDUCTION ACT POLICY A. Introduction. FEDERAL DEFICIT REDUCTION ACT POLICY Partnership for Children of Essex, Inc. (referred to herein as the Organization ) has instituted this Federal Deficit Reduction Act Policy as part

More information

Completing the Journey through the World of Compliance. Session # COM6, March 5, 2018 Gabriel L. Imperato, Managing Partner Broad and Cassel

Completing the Journey through the World of Compliance. Session # COM6, March 5, 2018 Gabriel L. Imperato, Managing Partner Broad and Cassel Completing the Journey through the World of Compliance Session # COM6, March 5, 2018 Gabriel L. Imperato, Managing Partner Broad and Cassel 1 Conflict of Interest Gabriel L. Imperato, Esq. (Certified in

More information

Medicare Parts C & D Fraud, Waste, and Abuse Training

Medicare Parts C & D Fraud, Waste, and Abuse Training Medicare Parts C & D Fraud, Waste, and Abuse Training IMPORTANT NOTE All persons who provide health or administrative services to Medicare enrollees must satisfy FWA training requirements. This module

More information

Vendor Information On Our Compliance Program

Vendor Information On Our Compliance Program Vendor Information On Our Compliance Program Version 1 April 13, 2009 Compliance Program Information for Vendors Table of Contents Page I. PURPOSE AND INTRODUCION 1 II. CODE OF CONDUCT: ETHICAL BEHAVIOR

More information

Compliance Program. Health First Health Plans Medicare Parts C & D Training

Compliance 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 information

Effective Date: 1/01/07 N/A

Effective Date: 1/01/07 N/A North Shore-LIJ Health System is now Northwell Health POLICY TITLE: Detecting and Preventing Fraud, Waste, Abuse and Misconduct POLICY #: 800.09 System Approval Date: 03/30/2017 Site Implementation Date:

More information

Institutional Compliance New Employee Orientation 2017

Institutional Compliance New Employee Orientation 2017 Institutional Compliance New Employee Orientation 2017 1 P R E S E N T E D B Y : D A R L E N E N O Y E S, R N, C H C, C C E P C O M P L I A N C E O F F I C E R F O R H O S P I T A L A F F A I R S L O R

More information

Policy to Provide Information for Combating Fraud, Waste and Abuse and the Ability of Employees to Report Wrongdoing

Policy 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 information

DEFICIT 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 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 information

SUNY DOWNSTATE MEDICAL CENTER POLICY AND PROCEDURE. No:

SUNY DOWNSTATE MEDICAL CENTER POLICY AND PROCEDURE. No: SUNY DOWNSTATE MEDICAL CENTER POLICY AND PROCEDURE Subject: Complying with the Deficit Reduction Act of 2005: Detection & Prevention of Fraud, Waste & Abuse Page 1 of 4 Prepared by: Shoshana Milstein Original

More information

SOUTH NASSAU COMMUNITIES HOSPITAL One Healthy Way, Oceanside, NY 11572

SOUTH NASSAU COMMUNITIES HOSPITAL One Healthy Way, Oceanside, NY 11572 SOUTH NASSAU COMMUNITIES HOSPITAL One Healthy Way, Oceanside, NY 11572 POLICY TITLE: Compliance with Applicable Federal and State False Claims Acts POLICY NUMBER: OF-ADM-232 DEPARTMENT: Hospital-wide BACKGROUND/PURPOSE

More information

C. Enrollees: A Medicaid beneficiary who is currently enrolled in the MCCMH PIHP.

C. Enrollees: A Medicaid beneficiary who is currently enrolled in the MCCMH PIHP. professionally recognized standards for health care. It also includes beneficiary practices that result in unnecessary cost to the Medicaid program. 42 CFR 455.2 B. CMS: Centers for Medicare & Medicaid

More information

Code of Conduct U.S. Supplemental Requirements

Code of Conduct U.S. Supplemental Requirements Our commitment to caring and curing Code of Conduct U.S. Supplemental Requirements US CoC Supplement_V6.indd 2 12/10/2011 10:05 Introduction These U.S. Supplemental Requirements to the Novartis Code of

More information

Repay Overpayments (18 USC 1347; 42 CFR et seq.)

Repay Overpayments (18 USC 1347; 42 CFR et seq.) Repay Overpayments (18 USC 1347; 42 CFR 401.301 et seq.) Repaying Overpayments If provider has received an overpayment, provider must: Return the overpayment to federal agency, state, intermediary, or

More information

Medicare Parts C & D Fraud, Waste, and Abuse Training and General Compliance Training

Medicare Parts C & D Fraud, Waste, and Abuse Training and General Compliance Training Medicare Parts C & D Fraud, Waste, and Abuse Training and General Compliance Training Developed by the Centers for Medicare & Medicaid Services Issued: February, 2013 Important Notice This training module

More information

Clinical and Administrative Policies and Procedures

Clinical and Administrative Policies and Procedures Clinical and Administrative Policies and Procedures Purpose: Centerstone is committed to its role in preventing health care fraud and abuse and complying with applicable state and federal law related to

More information

MENTAL HEALTH MENTAL RETARDATION OF TARRANT COUNTY. Board Policy. Number A.3 July 31, 2001 COMPLIANCE PLAN

MENTAL HEALTH MENTAL RETARDATION OF TARRANT COUNTY. Board Policy. Number A.3 July 31, 2001 COMPLIANCE PLAN MENTAL HEALTH MENTAL RETARDATION OF TARRANT COUNTY Board Policy Board Policy Adopted: Number A.3 July 31, 2001 OVERVIEW COMPLIANCE PLAN As adopted by the Board of Trustees on July 31, 2001 The Board of

More information

Medicare 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 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 information

DEFICIT 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 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 information

This course is designed to provide Part B providers with an overview of the Medicare Fraud and Abuse program including:

This course is designed to provide Part B providers with an overview of the Medicare Fraud and Abuse program including: This course is designed to provide Part B providers with an overview of the Medicare Fraud and Abuse program including: Medicare Trust Fund Defining Fraud & Abuse Examples of Fraud & Abuse Fraud & Abuse

More information

Industry Funding of Continuing Medical Education

Industry Funding of Continuing Medical Education Industry Funding of Continuing Medical Education June 25, 2010 Julie K. Taitsman, M.D., J.D. Chief Medical Officer, Office of Inspector General U.S. Department of Health and Human Services Financial Relationships

More information

Mission Statement. Compliance & Fraud, Waste and Abuse Training for Network Providers 1/31/2019

Mission Statement. Compliance & Fraud, Waste and Abuse Training for Network Providers 1/31/2019 Compliance & Fraud, Waste and Abuse Training for Network Providers Mission Statement To promote the quality of life of our communities by empowering others and working together to creatively solve unique

More information

Federal Deficit Reduction Act of 2005, Section 6032 on Fraud, Waste, and Abuse

Federal Deficit Reduction Act of 2005, Section 6032 on Fraud, Waste, and Abuse Policy Number: 4003 Page: 1 of 8 POLICY: It is the policy of Bridgeway Rehabilitation Services, Inc. to obey all federal and state laws and to implement and enforce procedures to detect and prevent fraudulent

More information

Developed by the Centers for Medicare & Medicaid Services Issued: February, 2013

Developed by the Centers for Medicare & Medicaid Services Issued: February, 2013 Medicare Parts C & D Fraud, Waste, and Abuse Training and General Compliance Training Developed by the Centers for Medicare & Medicaid Services Issued: February, 2013 Important Notice This training module

More information

Cedargate Health Care COMPLIANCE PROGRAM MANUAL CODE OF CONDUCT AND COMPLIANCE GUIDELINES

Cedargate Health Care COMPLIANCE PROGRAM MANUAL CODE OF CONDUCT AND COMPLIANCE GUIDELINES Cedargate Health Care COMPLIANCE PROGRAM MANUAL CODE OF CONDUCT AND COMPLIANCE GUIDELINES Page 1 of 18 OUR MISSION AND VALUES Cedargate Health Care is committed not only to providing residents with high

More information

Fraud and Abuse Compliance for the Health IT Industry

Fraud and Abuse Compliance for the Health IT Industry Fraud and Abuse Compliance for the Health IT Industry Session 89, March 6, 2018 James A. Cannatti III, Senior Counselor for Health Information Technology, U.S. Department of Health and Human Services (HHS),

More information

Amy Bingham, Compliance Director Reviewed Only Date: 6/05,1/31/2011, 1/24/2012 Supersedes and replaces: "CC-02 - Anti-

Amy 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 information

Federal Fraud and Abuse Enforcement in the ASC Space

Federal Fraud and Abuse Enforcement in the ASC Space Federal Fraud and Abuse Enforcement in the ASC Space SCOTT R. GRUBMAN, ESQ. PARTNER CHILIVIS COCHRAN LARKINS & BEVER, LLP (ATLANTA GA) Fraud & Abuse Enforcement Landscape FBI CMS OCR MFCU DCIS DOJ HHS-OIG

More information

STANDARDS OF CONDUCT

STANDARDS OF CONDUCT STANDARDS OF CONDUCT OVERVIEW At PacificSource Community Health Plans, Inc. and PacificSource Community Solutions, Inc. (collectively, PacificSource), our mission is to fully comply with all applicable

More information

PREVENTION, DETECTION, AND CORRECTION OF FRAUD, WASTE AND ABUSE

PREVENTION, DETECTION, AND CORRECTION OF FRAUD, WASTE AND ABUSE 1 of 9 PREVENTION, DETECTION, AND CORRECTION OF FRAUD, WASTE AND ABUSE 1. Purpose The purpose of this policy is to articulate commitment by Kaiser Permanente Hawaii Region to control fraud, waste and abuse

More information

CALIX, INC. ANTI-BRIBERY COMPLIANCE POLICY

CALIX, INC. ANTI-BRIBERY COMPLIANCE POLICY CALIX, INC. ANTI-BRIBERY COMPLIANCE POLICY 1.0 INTRODUCTION AND PURPOSE STATEMENT The Foreign Corrupt Practices Act ( FCPA ) is a US federal law that applies to both individuals and businesses. All Calix,

More information

False Claims Liability, Anti-Retaliation Protections, and Detecting and Responding to Fraud, Waste, and Abuse

False Claims Liability, Anti-Retaliation Protections, and Detecting and Responding to Fraud, Waste, and Abuse False Claims Liability, Anti-Retaliation Protections, and Detecting and Responding to Fraud, Waste, and 1. SCOPE 1.1 System-wide, including Marshfield Clinic Health System (MCHS), Inc. and its affiliated

More information

Effective Date: 5/31/2007 Reissue Date: 10/08/2018. I. Summary of Policy

Effective Date: 5/31/2007 Reissue Date: 10/08/2018. I. Summary of Policy Issuing Department: Internal Audit, Compliance, and Enterprise Risk Management Preventing Fraud, Waste, and Abuse: Federal and State False Claims and False Statements Effective Date: 5/31/2007 Reissue

More information

CORPORATE COMPLIANCE POLICY AND PROCEDURE

CORPORATE COMPLIANCE POLICY AND PROCEDURE Title: False Claims Act Policy Policy # 1011 Sponsor: Corporate Approved by: Kenneth J. Sodaro, Esq., Vice President, General Counsel & Corporate Secretary, Interim Officer Issued: Page: 1 of 5 June 25,

More information

Compliance Fraud, Waste and Abuse HIPAA Privacy and Security

Compliance Fraud, Waste and Abuse HIPAA Privacy and Security 2017 Compliance Fraud, Waste and Abuse HIPAA Privacy and Security Table of Contents/Agenda Welcome to General Compliance Training for Providers! Training Objectives: Understand why you need Compliance

More information

Developed by the Centers for Medicare & Medicaid Services

Developed by the Centers for Medicare & Medicaid Services Medicare Parts C and D Fraud, Waste, and Abuse Training Developed by the Centers for Medicare & Medicaid Services Why Do I Need Training? Every year millions of dollars are improperly spent because of

More information

Top 10 Issues in APM Contract Negotiations

Top 10 Issues in APM Contract Negotiations Legal Issues in New Contracting and Risk Sharing Models - What To Know Before You Sign Alexis Finkelberg Bortniker Foley & Lardner LLP 617-226-3177 Abortniker@foley.com June 2, 2017 Top 10 Issues in APM

More information

Charging, Coding and Billing Compliance

Charging, 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 information

Section (Primary Department) Medicaid Special Investigations Unit. Effective Date Date of Last Review 01/30/2015 Department Approval/Signature :

Section (Primary Department) Medicaid Special Investigations Unit. Effective Date Date of Last Review 01/30/2015 Department Approval/Signature : Medicaid Special Investigations Unit Medicaid Business Unit Date of Last Revision Dept. Approval Date Policy applies to Medicaid products offered by health plans operating in the following State(s) California

More information

POLICY & PROCEDURE. Policy Title: False Claims Prevention Effective Date: 3/20/2013. Department: Compliance Policy Number: N/A

POLICY & PROCEDURE. Policy Title: False Claims Prevention Effective Date: 3/20/2013. Department: Compliance Policy Number: N/A PURPOSE The purpose of this policy is to comply with certain requirements set for in the Deficit Reduction Act of 2005 with regard to federal and state false claims laws. SCOPE This policy applies to all

More information

Triad Healthcare Network Accountable Care Organization Participants

Triad Healthcare Network Accountable Care Organization Participants Triad Healthcare Network Accountable Care Organization Participants Code of Conduct V 052016 Board of Managers Approved May 24, 2016 TABLE OF CONTENTS A message from Steven Neorr... 2 INTRODUCTION... 3

More information

Dear Colleague, In the steadfast pursuit of excellence, I remain, Sincerely yours,

Dear Colleague, In the steadfast pursuit of excellence, I remain, Sincerely yours, Dear Colleague, Every employee, manager and physician plays a vital role in realizing Lifespan s mission: Delivering health with care. Essential to achieving this mission is Lifespan s continuous commitment

More information

Provider and Provider Relationships. Primary Fraud and Abuse Issues

Provider and Provider Relationships. Primary Fraud and Abuse Issues Provider and Provider Relationships Primary Fraud and Abuse Issues This document is intended to identify the primary healthcare fraud and abuse laws that may apply to contractual relationships between

More information

Health Law 101: Issue-Spotting In Dealing With Health-Care Providers. by William H. Hall Jr.

Health Law 101: Issue-Spotting In Dealing With Health-Care Providers. by William H. Hall Jr. Health Law 101: Issue-Spotting In Dealing With Health-Care Providers by William H. Hall Jr. The anti-kickback statute prohibits arrangements that might be common in other industries. Health care is among

More information

D E B R A S C H U C H E R T, C O M P L I A N C E O F F I C E R

D E B R A S C H U C H E R T, C O M P L I A N C E O F F I C E R D E B R A S C H U C H E R T, C O M P L I A N C E O F F I C E R INTEGRATED CARE ALLIANCE, LLC CORPORATE COMPLIANCE PROGRAM It is the policy of Integrated Care Alliance to comply with all laws governing

More information

Catholic Charities of the Roman Catholic Diocese of Syracuse, NY. Compliance Plan

Catholic Charities of the Roman Catholic Diocese of Syracuse, NY. Compliance Plan Catholic Charities of the Roman Catholic Diocese of Syracuse, NY Compliance Plan Corporate Board of Trustees Approval: Approved March 18, 2004 Revised and Approved December 19, 2007 Revised and Approved

More information

Corporate Compliance and Ethics Policy

Corporate Compliance and Ethics Policy ! United Methodist Memorial Home Corporate Compliance and Ethics Policy! 1 TABLE OF CONTENTS INTRODUCTION.. 3 CORPORATE COMPLIANCE & ETHICS OFFICER.. 4 BOARD OF TRUSTEES 4 GENERAL POLICY.. 5 POLICY STATEMENTS...

More information

False Claims Act and Whistleblower Protections

False Claims Act and Whistleblower Protections False Claims Act and Protections Date Implemented: 1/28/2009 Date Reviewed/ Revised: 9/5/2017 Reviewed/ Revised By: SR/KBJ Purpose: To satisfy requirements to provide information and education about False

More information

The False Claims Act and Off-Label Promotion: Understanding and Minimizing the Risks for Pharmaceutical Manufacturers

The False Claims Act and Off-Label Promotion: Understanding and Minimizing the Risks for Pharmaceutical Manufacturers 4th Annual Pharmaceutical Regulatory Congress November 12, 2003 The False Claims Act and Off-Label Promotion: Understanding and Minimizing the Risks for Pharmaceutical Manufacturers John T. Bentivoglio

More information

American Academy of Orthopaedic Surgeons 2010 Annual Meeting. March 12, 2010

American Academy of Orthopaedic Surgeons 2010 Annual Meeting. March 12, 2010 American Academy of Orthopaedic Surgeons 2010 Annual Meeting March 12, 2010 Developments in the Evolving Orthopaedic Surgeon - Industry Relationship Kathleen McDermott, Esquire Washington, DC 1 Developments

More information

FALSE CLAIMS ACT ENFORCEMENT: RECENT TRENDS AND STEPS TO ENSURE COMPLIANCE AND AVOID FRAUD ALLEGATIONS

FALSE CLAIMS ACT ENFORCEMENT: RECENT TRENDS AND STEPS TO ENSURE COMPLIANCE AND AVOID FRAUD ALLEGATIONS FALSE CLAIMS ACT ENFORCEMENT: RECENT TRENDS AND STEPS TO ENSURE COMPLIANCE AND AVOID FRAUD ALLEGATIONS The Carolinas Center s 39 th Annual Hospice & Palliative Care Conference Columbia, SC Presenters:

More information

ANTI-FRAUD PLAN INTRODUCTION

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 information

ZPIC Audits: What you Need to Know

ZPIC Audits: What you Need to Know ZPIC Audits: What you Need to Know Not representing CMS No outside affiliations Disclosures Kay Rankin, MD, CPC, CPC-H Medical Director, ZPIC 4 April, 2014 All Rights Reserved slide title pagemaster utilized

More information

MEDISYS AMBULANCE SERVICES, INC.

MEDISYS AMBULANCE SERVICES, INC. MEDISYS AMBULANCE SERVICES, INC. COMMITMENT TO COMPLIANCE CODE OF CONDUCT AND COMPLIANCE PROGRAM SUMMARY OCTOBER 2009 REVIEWED: 4/12, 10/13, 5/14, 6/15 REVISED: 8/12, 8/16, 7/17, 2/18 COMMITMENT TO COMPLIANCE

More information

COMPLIANCE TRAINING 2015 C O M P L I A N C E P R O G R A M - F W A - H I P A A - C O D E O F C O N D U C T

COMPLIANCE TRAINING 2015 C O M P L I A N C E P R O G R A M - F W A - H I P A A - C O D E O F C O N D U C T COMPLIANCE TRAINING 2015 QUALITY MANAGEMENT COMPLIANCE DEPARTMENT 2015 C O M P L I A N C E P R O G R A M - F W A - H I P A A - C O D E O F C O N D U C T Compliance Program why? Ensure ongoing education

More information

JAMAICA HOSPITAL MEDICAL CENTER

JAMAICA HOSPITAL MEDICAL CENTER JAMAICA HOSPITAL MEDICAL CENTER COMMITMENT TO COMPLIANCE CODE OF CONDUCT AND COMPLIANCE PROGRAM SUMMARY SEPTEMBER 2009 REVIEWED: 3/12, 9/13, 5/14, 6/15 REVISED: 8/12, 8/16, 7/17, 2/18 COMMITMENT TO COMPLIANCE

More information

Governance. Board of Directors. Ion Spor, President Steven Reeve, Director Will Spence, Secretary Terry Good Greg Meeker. Conflict of Interest Policy

Governance. Board of Directors. Ion Spor, President Steven Reeve, Director Will Spence, Secretary Terry Good Greg Meeker. Conflict of Interest Policy Governance Mountaintop Retreat OFBC Inc., is led by a Board of Directors with all of the powers of governing, directing and overseeing the management of the organization. The corporate governance principles

More information

PRYSMIAN ANTI-BRIBERY POLICY

PRYSMIAN ANTI-BRIBERY POLICY PRYSMIAN ANTI-BRIBERY POLICY All Prysmian Group employees must follow the Anti-Bribery Policy, and all applicable anti-bribery laws in the country(ies) in which they are employed or active, whichever is

More information

Compliance. Provider Manual

Compliance. Provider Manual Compliance Provider Manual Compliance This Manual was created to help guide you and your staff in understanding Kaiser Permanente s compliance policies and procedures. If, at any time, you have a question

More information

FAST BREAK : HOLIDAY GIFTS Jake Harper December 18, Morgan, Lewis & Bockius LLP

FAST BREAK : HOLIDAY GIFTS Jake Harper December 18, Morgan, Lewis & Bockius LLP FAST BREAK : HOLIDAY GIFTS Jake Harper December 18, 2018 2018 Morgan, Lewis & Bockius LLP Agenda Holiday Gifts and the Laws They May Trigger Stark Beneficiary Inducement CMP AKS One-purpose Test Considerations

More information

COMPLIANCE DEPARTMENT. LSUHSC-S Louisiana State University Health Sciences Center Shreveport ACKNOWLEDGEMENT RECEIPT

COMPLIANCE DEPARTMENT. LSUHSC-S Louisiana State University Health Sciences Center Shreveport ACKNOWLEDGEMENT RECEIPT COMPLIANCE DEPARTMENT LSUHSC-S Louisiana State University Health Sciences Center Shreveport ACKNOWLEDGEMENT RECEIPT for COMPLIANCE, HIPAA PRIVACY, AND INFORMATION SECURITY SELF-STUDY GUIDE I hereby certify

More information

Global Anti-Bribery Policy

Global Anti-Bribery Policy Global Anti-Bribery Policy A. Introduction Power Corporation of Canada ( Power Corporation or the Corporation ) and its Board of Directors are committed to carrying out business worldwide ethically and

More information

VNSNY Compliance Orientation

VNSNY Compliance Orientation VNSNY Compliance Orientation 2016-2017 VNSNY COMPLIANCE ORIENTATION CONTENT 1. General Compliance Orientation Training a. Code of Conduct b. HIPAA c. HIV Confidentiality 2. Corporate Policies and Procedures

More information

Compliance 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 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 information

FWA (Fraud, Waste and Abuse) Training

FWA (Fraud, Waste and Abuse) Training FWA (Fraud, Waste and Abuse) Training Why Do I Need Training or Re Training? Every year billions of dollars are improperly spent because of FWA. It affects everyone including you. This training will help

More information

Corporate Integrity Department

Corporate Integrity Department Corporate Integrity Department 2018 Volunteer Compliance Training Introduction This self-guided training module will educate you on CoxHealth s Corporate Compliance Program, The Code of Business Conduct

More information

Medicare Parts C & D General Compliance Training

Medicare Parts C & D General Compliance Training Medicare Parts C & D General Compliance Training Developed by the Centers for Medicare & Medicaid Services Issued: February, 2013 Part 2: Medicare Parts C & D Compliance Training Developed by the Centers

More information

Global Policy on Anti-Bribery and Anti-Corruption

Global Policy on Anti-Bribery and Anti-Corruption 1 Global Policy on Anti-Bribery and Anti-Corruption OUR GLOBAL POLICY ON ANTI-BRIBERY AND ANTI-CORRUPTION Did You know?? PolyOne is committed to the prevention, deterrence and detection of fraud, bribery

More information

Automatic Data Processing, Inc. ADP Anti-Bribery Policy

Automatic Data Processing, Inc. ADP Anti-Bribery Policy Automatic Data Processing, Inc. ADP Anti-Bribery Policy Adopted August 2008 Revised November 17, 2009 and August 9, 2011 Statement by Chief Executive Officer AUTOMATIC DATA PROCESSING, INC. ANTI-BRIBERY

More information

HOSPITAL COMPLIANCE POTENTIAL IMPLICATION OF FRAUD AND ABUSE LAWS AND REGULATIONS FOR HOSPITALS

HOSPITAL COMPLIANCE POTENTIAL IMPLICATION OF FRAUD AND ABUSE LAWS AND REGULATIONS FOR HOSPITALS HOSPITAL COMPLIANCE H C C A R E G I O N A L C O N F E R E N C E A P R I L 2 8, 2 0 1 6 S A N J U A N, P U E R T O R I C O S A N C H E Z B E T A N C E S, S I F R E & M U Ñ O Z N O Y A, C S P J A I M E S

More information

GLOBAL ANTI-CORRUPTION POLICY

GLOBAL ANTI-CORRUPTION POLICY GLOBAL ANTI-CORRUPTION POLICY Version of March, 2017 Policy Owner: VP Integrity and Legal Compliance Date Change log March 31 st 2017 Policy release Global Anti-Corruption Policy Page 1 Subject Page 1.

More information

Region 10 PIHP FY Corporate Compliance Program Plan

Region 10 PIHP FY Corporate Compliance Program Plan Region 10 PIHP FY 2018 Corporate Compliance Program Plan 1 Mission The purpose of the Region 10 Corporate Compliance Program Plan is to provide quality care for all the individuals it serves by acting

More information

Improving Integrity in Nursing Centers

Improving Integrity in Nursing Centers Improving Integrity in Nursing Centers Susan Edwards Reed Smith LLP AHCA/NCAL s General Counsel Goals of this webinar Introduce you to AHCA/NCAL s Fraud and Abuse Toolkit Provide you with a basic understanding

More information

Disclaimer LEGAL ISSUES IN PHYSICAL THERAPY

Disclaimer LEGAL ISSUES IN PHYSICAL THERAPY LEGAL ISSUES IN PHYSICAL THERAPY Paul J. Welk, PT, JD Tucker Arensberg, P.C. pwelk@tuckerlaw.com 2017 PHCA Annual Convention 1 Disclaimer The purpose of this presentation is to provide a general overview

More information

CODE OF CONDUCT AND ETHICS

CODE OF CONDUCT AND ETHICS CODE OF CONDUCT AND ETHICS Updated: August 2017 Please contact the Office of Legal Services with questions about this policy. The public purpose and tax-exempt status of the foundation includes an obligation

More information

ANCILLARY services: How to Stay Out of Trouble. The neurosurgical minefield Informed consent

ANCILLARY services: How to Stay Out of Trouble. The neurosurgical minefield Informed consent ANCILLARY services: How to Stay Out of Trouble Richard N.W. Wohns, M.D. JD, MBA NeoSpine, Puget Sound Region, Washington The neurosurgical minefield 2013 Informed consent HIPAA ARRA and HITECH Anti-Kickback

More information

False Claims Prevention

False Claims Prevention False Claims Prevention POLICY STATEMENT It is the policy of Atrium Health & Senior Living ( Atrium ) to put into practice procedures designed to detect and prevent fraud, waste and abuse, and to maintain

More information

TORONTO PORT AUTHORITY CODE OF BUSINESS CONDUCT AND ETHICS. November 29, 2005

TORONTO PORT AUTHORITY CODE OF BUSINESS CONDUCT AND ETHICS. November 29, 2005 TORONTO PORT AUTHORITY CODE OF BUSINESS CONDUCT AND ETHICS November 29, 2005 CODE OF BUSINESS CONDUCT AND ETHICS... 2 SUMMARY OF CODE OF BUSINESS CONDUCT AND ETHICS... 2 EXPLANATION OF THE CODE... 3 1.

More information

THE NEW YORK FOUNDLING

THE NEW YORK FOUNDLING THE NEW YORK FOUNDLING COMMITMENT TO COMPLIANCE HANDBOOK CODE OF CONDUCT AND COMPLIANCE STANDARDS COMPLIANCE PROGRAM STRUCTURE AND GUIDELINES POLICIES AND PROCEDURES December 2012 COMMITMENT TO COMPLIANCE

More information

THIRD PARTY CODE OF CONDUCT

THIRD PARTY CODE OF CONDUCT THIRD PARTY CODE OF CONDUCT TABLE OF CONTENTS Message from the CEO...2 Coverage and Scope of the Code...2 Compliance with The Code...2 Anti-Corruption Policies and Improper Payments...3 Financial Integrity

More information

i!lsms CODE OF CONDUCT POLICY

i!lsms CODE OF CONDUCT POLICY i!lsms SPECIALIZED MEDICAL SEltVlCES ~NEW POLICY AND PROCEDURE 0 REVISION DATE: CODE OF CONDUCT POLICY Specialized Medical Services, Inc. ("SMS") has adopted a comprehensive "Corporate Compliance Program"

More information

ProMedica Compliance Plan Supplement

ProMedica Compliance Plan Supplement E X H I B I T A ProMedica Compliance Plan Supplement Plan Summary & Employee Guide This document supplements the ProMedica Compliance Plan and is specifically limited to operations conducted at Paramount

More information

7/25/2018. Government Enforcement in the Clinical Laboratory Space. The Statutes & Regulations. The Stark Law. The Stark Law.

7/25/2018. Government Enforcement in the Clinical Laboratory Space. The Statutes & Regulations. The Stark Law. The Stark Law. Government Enforcement in the Clinical Laboratory Space 2 SCOTT R. GRUBMAN, ESQ. The Statutes & Regulations 3 4 AKA the physician self-referral law The Rule: If physician (or immediate family member) has

More information

POLICY. Tiger Brands Anti-Bribery and Anti-Corruption Policy

POLICY. Tiger Brands Anti-Bribery and Anti-Corruption Policy and Anti- TABLE OF CONTENTS DOCUMENT CONTROL INFORMATION... 3 1 INTRODUCTION... 5 2 SCOPE... 5 3 OBJECTIVE... 5 4 POLICY DETAILS... 6 5 ROLES AND RESPONSIBILITIES... 10 6 COMPLIANCE... ERROR! BOOKMARK

More information

Gifts to Referral Sources. Kim C. Stanger (11-17)

Gifts to Referral Sources. Kim C. Stanger (11-17) Gifts to Referral Sources Kim C. Stanger (11-17) Overview Some relevant laws Applying those laws to common situations Gifts to or from referral sources Gifts to physicians Gifts to or from patients Gifts

More information