Dear Valued Contractor or Agent of Princeton HealthCare System:
The Deficit Reduction Act (DRA) of 2005 mandates that effective January 1, 2007, Princeton HealthCare System (PHCS) as a healthcare provider receiving annual payments under the State Medicaid plan of at least $5 million must:
- Establish written policies for all employees of the entity (including management), and of any contractor or agent of the entity, that provide detailed information about the False Claims Act (FCA) and any State laws pertaining to civil or criminal penalties for false claims and statements, and whistleblower protections under such laws, with respect to the role of such laws in preventing and detecting fraud, waste, and abuse in federal health care programs.
- Include as part of such written policies, detailed provisions regarding the entity’s policies and procedures for detecting and preventing fraud, waste and abuse.
Princeton HealthCare System supports the efforts of federal and state authorities in identifying incidents of fraud and abuse and has the necessary procedures in place to prevent, detect, report and correct incidents of fraud and abuse in accordance with contractual, regulatory and statutory requirements.
As a contractor or agent of PHCS, we are notifying you of the PHCS False Claims Act Policy, which sets forth the guidelines that all employees, contractors and agents are required to follow to assure compliance with the FCA and to detect and prevent fraud, waste and abuse. Please disseminate this letter and make the PHCS FCA policy available to all of your employees who provide services to PHCS.
Under the FCA, it is a violation to knowingly submit a false claim to the government. All employees, contractors or agents with knowledge of potential fraud and abuse situations must report such situations through either of the following methods:
- Contacting the PHCS Chief Compliance Officer/Corporate Compliance Office directly at 609-853-7140 or
- Calling the confidential PHCS Compliance Hotline at 1-800-779-4035.
Retaliation or retribution for reporting issues “in good faith” is prohibited at PHCS.
Below please find some examples of Health Care Fraud that may lead to the submission of fraudulent claims to the government:
- Falsifying billing and/or medical coding records;
- Billing for services not medically necessary;
- Duplicate billing for items or services;
- Submitting bills for services never performed or items never furnished;
- Failing to report overpayments.
If you have any questions about this policy, contact Nancy Fletcher, PHCS Compliance and Privacy Officer, at 609.853.7140. To download our FCA policy, click here.