{"ref":"MI-HH-ETH-01","title":"Compliance Program, Exclusion Screening, and False Claims Prevention","category":"Ethics","summary":"Sets out the Agency’s compliance program: a code of conduct, a person responsible for compliance, confidential reporting without retaliation, screening of staff, contractors and governing body members against the federal exclusion list, SAM.gov and the MDHHS Sanctioned Provider List, auditing and monitoring, investigation and correction, and education about the federal False Claims Act and Michigan’s Medicaid False Claim Act, so that findings of fraud or waste are appropriately addressed (42 CFR §484.65(e)(4)).","inShort":["Bill and document honestly. Never back-date or change a record to support a bill.","Everyone who works with us is checked every month against federal and Michigan exclusion lists.","Report any concern about fraud to the Administrator, or call the Medicaid fraud line: MDHHS Office of Inspector General, 1-855-MI-FRAUD (1-855-643-7283), www.michigan.gov/fraud.","You cannot be punished for reporting in good faith.","Tell the Administrator at once if you are excluded or sanctioned."],"primaryCitation":"42 CFR §1001.1901","citations":["Medicaid False Claim Act, MCL 400.601 et seq.","MCL 400.604","MCL 400.610c","Health Care False Claim Act, MCL 752.1001 et seq.","Michigan Medicaid Provider Manual, General Information for Providers, Section 6","Michigan Medicaid Provider Manual, General Information for Providers, Section 7.1","Michigan Medicaid Provider Manual, General Information for Providers, Section 15"],"federalCitations":["42 CFR §1001.1901","42 CFR §424.516(a)(3)","42 CFR §484.105(e)(2)","42 CFR §484.65(e)(4)","42 CFR §401.305","31 U.S.C. §3729","31 U.S.C. §3730(h)","42 U.S.C. §1320a-7","42 U.S.C. §1396a(a)(68)"],"surveyorAsks":["Who is responsible for compliance, and how do staff report a concern?","Show me your exclusion screening log for the last three months."],"forms":[{"ref":"MI-HH-ETH-01-A","title":"Exclusion and Sanction Screening Log"}],"headings":["Terms of Reference","1. Purpose","2. Scope","3. Definitions","4. Policy Statement (42 CFR §1001.1901, 42 CFR §484.65(e)(4) and the Michigan Medicaid Provider Manual)","5. Compliance Officer and Oversight","6. Code of Conduct","7. Reporting Concerns and Non-Retaliation","8. Exclusion and Sanction Screening","9. If a Match Is Found","10. Auditing, Investigation, and Correction","11. False Claims Education","12. Responsibilities","13. Records and Compliance Monitoring","14. Staff Training","15. References","16. Related Policies and Forms","17. Approval","18. Revision History"],"version":"1.0","sample":false,"pack":"mi-hha","state":"Michigan","service":"Home health","guides":[{"path":"/guides/home-health-agency-policies/","h1":"What policies and procedures are required for home health agencies?"},{"path":"/guides/home-health-conditions-of-participation/","h1":"Home health Conditions of Participation: which policies each one needs"}],"agency":{"name":"Sample Agency","legalName":"Sample Agency, LLC","logo":null}}