Policy: Heartland Residential Services (“Heartland”) is committed to its role in preventing health care fraud and abuse and complying with the applicable state and federal laws related to health care fraud, waste and abuse. The Deficit Reduction Act of 2005 requires information about the federal False Claims Act and other laws, including state laws, dealing with fraud, waste, and abuse and whistleblower protections for reporting those issues, to be disseminated to all employees, contractors and/or agents.
To ensure compliance with this requirement and all state and federal laws pertaining to fraud, waste and abuse, Heartland has implemented policies and procedures designed to detect and prevent the same. Further, Heartland supports the efforts of federal and state authorities in identifying incidents of fraud and abuse.
- Detection of fraud and waste. Heartland shall compare documentation of service hours provided to hours billed on a regular basis, but no less than once a month. In those instances where fraud or false reporting of services provided is suspected or detected Heartland shall:
- Immediately conduct an investigation in order to determine if a partial or full audit is necessary, and if so whether it is related to a single employee or individual receiving services, or multiple employees and/or individuals. Such investigation shall be completed no more than five (5) business days after learning of the suspected or actual fraud.
- Audit all relevant time keeping, billing and financial records. Any amounts determined to be over-billed shall be immediately returned to the state.
- Report any individual identified to have committed, and/or assisted in the commitment of, Medicaid fraud to the appropriate authorities, including: the Indiana Attorney General’s Office, Office of Medicaid Fraud; the Office of Inspector General; CMS; BQIS; and, local law enforcement.
- Heartland shall provide all employees, contractors and/or agents with a notice outlining the contents of the federal and state laws, including administrative remedies and whistleblower protections. This notice shall be provided at all initial Training and Orientation classes, and the general contents of the Notice and the Act shall be contained in the Employee Handbook.
- Code of Ethics. Heartland shall ensure that a company Code of Ethics is created and reviewed/updated on an annual basis, or more frequently as circumstances require. A copy of this Code shall be provided to all employees, contractors and/or agents for review and signature:
- During initial training
- During mandatory annual training; and,
- During re-training of an individual employee, as applicable.