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ICS.01.39, Waste, Fraud & Abuse Training This module will present education concerning False Claims Liability, Anti-retaliation Protections as well as detecting and responding to Fraud, Waste and Abuse.
Authorizes data sharing between Medicare and Medicaid;
Increases the States’ requirements to fight fraud and abuse activities within their State Medicaid plans;
Requires entities to provide compliance education related to the False Claims Act.
The DRA indirectly mandates a compliance program which requires that staff must be informed about the False Claims Act, Administrative remedies under the Act, relevant State Laws and Whistleblowers’ protection.
The compliance plan establishes activities that assist in avoiding and identifying activities that could be considered violations of fraud and abuse laws, such as, auditing, implementing practice standards, implementing appropriate response mechanisms to reports, developing open lines of communications and encouraging the reporting of fraud and abuse, as well as the designation of a Compliance Officer who monitors all related activities in the program.
ICS.01.39 , Fraud and Abuse Guideline outlines the ICS policy for fraud and abuse. It identifies the Business Services Unit as the Compliance Officer for the program. This entity will:
Promptly investigate every report of any violation regarding claims fraud and/or abuse.
Promptly refer all verified cases of fraud and abuse to the Medicaid Fraud Control Unit (MFCU) and the DHS Provider Audit Unit.
Maintain a file to track the disposition of all reports and investigations .
Disciplinary Guidelines for violations of the fraud and abuse policy include punitive actions up to and including termination of association with ICS and any appropriate and imposed criminal penalties through the justice system.
Any client, employee or contractor of ICS who reports information regarding potential fraud, waste or abuse will have the right to do so anonymously and will be protected against retaliation for coming forward with such information both under internal Multnomah County Policies and under State and Federal Laws.
Retaliation directed at reporters of fraud, waste and abuse is unlawful; see ORS 659A.203 – http://www.leg.state.or.us/ors/659a.html
This completes the Fraud, Waste & Abuse Training Module