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Regional Generic Provider Agreement - Ohio Department of Job and ...

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Appendix I<br />

Covered Families <strong>and</strong> Children population<br />

Page 1<br />

APPENDIX I<br />

PROGRAM INTEGRITY<br />

CFC ELIGIBLE POPULATION<br />

MCPs must comply with all applicable program integrity requirements, including those specified<br />

in 42 CFR 455 <strong>and</strong> 42 CFR 438 Subpart H.<br />

1. Fraud <strong>and</strong> Abuse Program:<br />

In addition to the specific requirements <strong>of</strong> OAC rule 5101:3-26-06, MCPs must have a<br />

program that includes administrative <strong>and</strong> management arrangements or procedures,<br />

including a m<strong>and</strong>atory compliance plan to guard against fraud <strong>and</strong> abuse. The MCP’s<br />

compliance plan must designate staff responsibility for administering the plan <strong>and</strong><br />

include clear goals, milestones or objectives, measurements, key dates for achieving<br />

identified outcomes, <strong>and</strong> explain how the MCP will determine the compliance plan’s<br />

effectiveness.<br />

In addition to the requirements in OAC rule 5101:3-26-06, the MCP’s compliance<br />

program which safeguards against fraud <strong>and</strong> abuse must, at a minimum, specifically<br />

address the following:<br />

a. Employee education about false claims recovery: In order to comply with<br />

Section 6032 <strong>of</strong> the Deficit Reduction Act <strong>of</strong> 2005 MCPs must, as a condition <strong>of</strong><br />

receiving Medicaid payment, do the following:<br />

i. establish <strong>and</strong> make readily available to all employees, including the<br />

MCP’s management, the following written policies regarding false claims<br />

recovery:<br />

a. detailed information about the federal False Claims Act <strong>and</strong> other state<br />

<strong>and</strong> federal laws related to the prevention <strong>and</strong> detection <strong>of</strong> fraud, waste,<br />

<strong>and</strong> abuse, including administrative remedies for false claims <strong>and</strong><br />

statements as well as civil or criminal penalties;<br />

b. the MCP’s policies <strong>and</strong> procedures for detecting <strong>and</strong> preventing fraud,<br />

waste, <strong>and</strong> abuse; <strong>and</strong><br />

c. the laws governing the rights <strong>of</strong> employees to be protected as<br />

whistleblowers.<br />

ii. include in any employee h<strong>and</strong>book the required written policies regarding<br />

false claims recovery;<br />

iii. establish written policies for any MCP contractors <strong>and</strong> agents that provide<br />

detailed information about the federal False Claims Act <strong>and</strong> other state<br />

<strong>and</strong> federal laws related to the prevention <strong>and</strong> detection <strong>of</strong> fraud, waste,

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