Background
Section 6032 of the Deficit Reduction Act of 2005 requires healthcare services providers like PPCH to educated employees and contractors on federal and state laws concerning the submission of false and fraudulent claims for payment to the government. These laws play a central role in the government’s efforts to prevent and detect fraud, waste, and abuse in federal healthcare programs.
Scope
This policy applies to all directors, officers, administrators, managers, staff, employees, contractors, and agents who provide billing or healthcare services on behalf of PPCH. It has long been the policy of PPCH to comply with all applicable federal and state laws and regulations, including those related to the submission of claims and other documentation to state and federal healthcare programs. In order to comply with Section 6032 of the Deficit Reduction Act of 2005, PPCH shall ensure that all employees, including management, contractors, and agents, are provided with information regarding federal and state false claims statutes.
Procedure
PPCH will educate employees, including management, contractors, and agents who provide billing or healthcare services on behalf of PPCH, on federal and state false claims statutes. All contractors and agents are required to review the policy.
PPCH will ensure that
- All employees are provided with a copy of PPCH’s Fraud, Waste, and Abuse Policy within 30 days of employment with PPCH
- PPCH’s Employee Handbook will incorporate Policy information, to be regularly revised and updated
- PPCH’s Policy will be provided via email to all contractors and agents who provide billing or healthcare services on behalf of PPCH
All employees are responsible for understanding the Policy and directing questions to appropriate management personnel.
Violations of the Colorado Medicaid False Claims Act are civil offenses and are punishable by significant monetary penalties.
Reporting
PPCH takes issues regarding false claims, fraud, and abuse very seriously. PPCH encourages all employees, contractors, and agents to be aware of the laws regarding fraud, abuse, and false claims and to resolve any issues immediately. Issues are resolved most quickly and most effectively when the leadership team is given prompt notice of the concern. Report all concerns to an immediate supervisor or appropriate contact. If an employee, contractor, or agent does not feel that PPCH has responded quickly and appropriately to the concern, the individual is encouraged to discuss the situation with the next highest level of leadership, or with a government agency directly.
Policies and Procedures
PPCH is committed to conducting business activities in an ethical and forthright manner and within the letter and spirit of all applicable laws and regulations. PPCH has adopted an Employee Handbook that elaborates on its commitment to ethical business practices. PPCH prohibits retaliation against employees for reporting waste, fraud, and abuse, or for engaging in legal activities related to False Claims Act action.
References:
Colo. Rev. Stat. §§ 25.5.303.5 through 310 (previously codified at Colo. Rev Stat. §§ 26-4-1101 et seq.)
Senate Bill 10-167 (Colo. 2010)
Civil False Claims Act, 31 U.S.C. §§ 3729-33
Deficit Reduction Act of 2005, Sections 6031, 6032 (Public Law No. 109-171)
Parker Personal Care Homes, Inc. Employee Handbook