Compliance Program, Exclusion Screening, and False Claims Prevention

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)).

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About this policy

Policy number: MI-HH-ETH-01
Version: 1.0
Main rule: 42 CFR §1001.1901
Library: Michigan home health · 57 policies
Category: Ethics
Sections: 19

In short

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.

What's inside

19 sections. The full text comes with the One-time Policy Pack.

Full text with a package

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

An inspector may ask

Who is responsible for compliance, and how do staff report a concern?
Show me your exclusion screening log for the last three months.

Michigan home health

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Rules it follows

42 CFR §1001.1901Medicaid False Claim Act, MCL 400.601 et seq.MCL 400.604MCL 400.610cHealth Care False Claim Act, MCL 752.1001 et seq.Michigan Medicaid Provider Manual, General Information for Providers, Section 6Michigan Medicaid Provider Manual, General Information for Providers, Section 7.1Michigan Medicaid Provider Manual, General Information for Providers, Section 1542 CFR §424.516(a)(3)42 CFR §484.105(e)(2)42 CFR §484.65(e)(4)42 CFR §401.30531 U.S.C. §372931 U.S.C. §3730(h)42 U.S.C. §1320a-742 U.S.C. §1396a(a)(68)

Forms included

MI-HH-ETH-01-A Exclusion and Sanction Screening Log

Read a sample in full

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