Corporate Responsibility - Ascension Health

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L A W S A N D R E G U L A T I O N SWe create accurate and truthful patient bills and submitaccurate claims for payment from any payer, includingMedicare and Medicaid, commercial insurance or ourpatients. Not only is it the right thing to do, but federaland state laws require accuracy in healthcare billing.The False Claims Act is a federal law that makes it acrime for any person or organization to knowingly makea false record or file a false claim with the governmentfor payment. “Knowingly” includes having actualknowledge that a claim is false, or acting in “deliberateignorance” or “reckless disregard” as to whether a claimis false. Examples of possible false claims include billingFinancial penalties to the organization for submitting afalse claim can total as much as three times the amountof the claim plus fines of $5,500 to $11,000 per claim.In addition to fines and penalties, an individual ororganization that violates the False Claims Act issubject to exclusion from participation in federallyfunded healthcare programs.C O R P O R A T E R E S P O N S I B I L I T YMedicare for services that were not provided, billing fora higher-level service than the service actually furnished(upcoding) or billing for services that were not orderedby a physician.The False Claims Act contains provisions that allowindividuals with original information (i.e., information notalready the subject of legal proceedings or activitiesthat have already been publicly disclosed) concerningfraud involving government programs to file a lawsuiton behalf of the government and, if the lawsuit issuccessful, to receive a portion of recoveries obtainedby the government.
The federal False Claims Act protects an employeefrom being fired, demoted, threatened or harassed by hisor her employer for providing information in good faithrelative to a False Claims Act investigation or lawsuit.The Program Fraud Civil Remedies Act (“PFCRA”)provides federal agencies, including the agenciesresponsible for federally funded healthcare programs,with administrative remedies against individuals andorganizations that knowingly submit a false claim forpayment, or knowingly make or use a false record orstatement to get a false claim paid. The PFCRA islimited to situations where a false claim, or a groupof related false claims, does not exceed $150,000.The PFCRA provides civil penalties up to $6,000 perfalse claim, plus an assessment equal to twice theamount of the false claim.In addition to the federal law, certain states haveadopted a similar law that allows individuals or theState to file a lawsuit in state court for false claimsfiled with the state for payment, such as the Medicaidprogram. Your Corporate Responsibility Officer candescribe the False Claims Act provisions applicable toyour state.Our Corporate Responsibility Program supportscompliance with these federal and state laws by:Monitoring and auditing to prevent or detecterrors in coding or billing.Educating our associates that they areresponsible for reporting any concern abouta possible false claim.Investigating all reported concerns and correctingany billing errors discovered.Protecting our associates who report concernsin good faith.6 7
Page 4 and 5: The following six Standards of Cond
Page 6 and 7: L A W S A N D R E G U L A T I O N S
Page 10 and 11: H U M A NR E S O U R C E SAscension
Page 12 and 13: C O N F I D E N T I A L I T YIn kee
Page 14 and 15: We may face circumstances that can
Page 16 and 17: ConclusionOur Mission, Vision and V
Page 19 and 20: Values LineA M I S S I O N B A S E

Corporate Responsibility - Ascension Health

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