Question

In regards to Healthcare Compliance: What is the purpose of a Special Fraud Alert? Who is likely to receive copies of the alerts and what will they do with them?

Answer 1

Ans) The Special fraud alert addresses compliance concerns, such as compensation paid by laboratories to referring physicians and physician group practices for blood specimen collection, processing and packaging and for submitting patient data to registry or database.

- The OIG has designed and issued special fraud alerts to the health care provider community for the last 20 years.

What happens in this process:

- OIG has a self disclosure protocol, CMS has a self referral disclosure protocol, department of justice, state Attorney General's office, Medicaid fraud control unit.

OIG's voluntary self disclosure protocol:

- This protocol established guidelines for conducting an internal investigation and financial assessments. The OIG has an online self disclosure protocol submission form on its website.

- Damages are to be calculated after an initial submission of the self disclosure in 90 days. The self disclosure protocol establishes damages calculation methodology and specific information requirements for matters involving false billing, conduct including excluded persons, and anti-kickback statute or stark issues.

- After a self disclosure, Provider should conduct an internal investigation and self-assessment.

- In making a voluntary self disclosure, the healthcare provider is demonstrating its commitment to ethical behavior and fair dealing this with the federal healthcare programs. It also demonstrates an effective compliance program and may decrease damages. It may also limit exposure for prior problems and cut off potential whistleblowers.