Question

Describe in detail three specific management actions or remedial steps to take to ensure the financial management in the healthcare organization meets or exceeds the requirements relative to the False Claims Act.  

Answer 1

How can MANAGEMENT help avoid violations of the False Claims Act?

There are several things you can do to reduce the risk of False Claims Act liability. First, you should make sure you understand the rules that relate to the services and goods being billed. Information contained in any claim must be as accurate and complete as possible. Specifics about correct billing may be obtained from:

• The Centers for Medicare and Medicaid Services
• The New York State Medicaid program
• Medicare Administrative Contractor - National Government Services, Inc.
• The New York State Department of Health

You may also receive assistance from the Compliance Office by calling (585) 275-1609.

Second, if you become aware of a potential billing problem, you should immediately notify your supervisor, the Compliance Office or the Integrity Hotline at (585) 756-8888 or integrityhotline.urmc.edu. It is important to act swiftly so the matter can be reviewed, and the proper action is taken. Potential actions include:

• Making changes to prevent the problem from continuing
• Making arrangements to repay any overpayments
• When appropriate, disclosing the problem to the appropriate state and federal officials

By voluntarily disclosing such information, URMC or its the affiliate may be able to avoid liability or at least limit liability under the False Claims Act.