By Mark Wright, OD, FCOVD,
and Carole Burns, OD, FCOVD
Oct. 2, 2019
Each year the Department of Health and Human Services, as well as the Department of Justice, publish a Health Care Fraud and Abuse Control Program Report for the fiscal year. There are a couple of statements contained in the 2018 Annual Report that got our attention.i
1) During Fiscal Year (FY) 2018, the Federal Government won, or negotiated, over $2.3 billion in health-care fraud judgments and settlements.
2) The return on investment (ROI) for the HCFAC program over the last three years (2016-2018)) is $4 returned for every $1 expended.
These two facts tell us that the government is watching and that the government is pretty good at getting a good return on its investment. Invest $1 and get $4 back. This is a positive revenue stream for the government.
Consider the case of Matilda Lynn Prince, who was convicted in 2018 by a federal jury of 29 counts of health-care fraud for filing fraudulent claims with Medicare and the Georgia Medicaid program for services that were never provided to patients.ii She was sentenced to three years, four months in prison, to be followed by three years of supervised release, and ordered to pay restitution in the amount of $609,000.
Other Articles to Explore
“This sentence sends a clear-cut message to crooked providers who fraudulently bill government health-care programs,” said Derrick L. Jackson, Special Agent in Charge for the U.S. Department of Health & Human Services – Office of Inspector General (OIG). “The OIG and our law enforcement partners will continue to aggressively pursue these thieves to ensure they are held accountable.”iii
Knowing that the government is watching, what systems do you have in place in your office to make sure that you are following the rules?
Here are the seven steps the government “suggests” you followiv:
1) Conduct internal monitoring and auditing
2) Implement compliance and practice standards
3) Designate a compliance officer or contact
4) Conduct appropriate training and education
5) Respond appropriately to detected offenses and develop corrective action
6) Develop open lines of communication
7) Enforce disciplinary standards through well-publicized guidelines
Click on the link HERE to read the original document published in the Federal Register to make sure you know what each step means, and then review these seven steps at least annually to make sure you are actively following this system.