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

Emailmhcompofcr@co.shasta.ca.us

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?