Throughout our history, one of Northwest Community Healthcare’s core values has been to maintain the highest levels of ethical behavior in every aspect of our operations. With this in mind, we believe it is important to make certain that all key business partners have the information needed to assist us with compliance of Section 6032 of the Federal Deficit Reduction Act (DRA) of 2005 (effective January 1, 2007). On this web page, we are addressing many of the questions and concerns surrounding the DRA and the State of Illinois and Federal False Claims Acts.
Additionally, NCH has created two new policies that detail the requirements of the DRA.
Regarding the State of Illinois and Federal False Claims Acts and the Deficit Reduction Act
A false claim is a claim that is inaccurate and thereby prevents the government from obtaining the money to which it is entitled. These include, but are not limited to, the following:
The False Claims Acts are what the government uses to take action against healthcare providers that engage in inappropriate conduct usually associated with charging, billing and coding mistakes. It is designed to promote compliance with state and federal laws. The False Claims Acts are important because they are meant to help ensure ethical and honest business dealings with the government and the best possible service for our patients. Northwest Community Hospital believes in and supports all employees in doing the right thing for the right reason.
In 2006, President George W. Bush signed the Deficit Reduction Act (DRA). It required that by January 1, 2007, Northwest Community Hospital establish written policies that:
Steps have been taken to ensure that NCH meets all of these requirements.
A “whistleblower” is one who reveals wrongdoing within an organization to the government or those in a position of authority. However, an individual must first reasonably believe that a violation of law, gross mismanagement, gross waste of funds, abuse of authority, or substantial and specific danger to public safety or health occurred.
Vendors are encouraged to communicate problems, complaints and concerns about suspected unlawful practices.
Federal and state whistleblower statutes protect an individual who has initiated an investigation of an employer’s activities or who has cooperated with a regulatory agency in carrying out an inquiry or the enforcement of regulations from discharge or discrimination. In addition, NCH has a policy of non-retaliation that protects the whistleblower who, in good faith, brings forward suspicions of unlawful activity.
The DRA requirements apply specifically to Medicaid providers that receive more than $5 million annually in reimbursement payments from the program. However, the False Claims Acts apply to all state and federal program payments and include private payers.
More detailed information may be found on pertinent NCH policies and procedures by calling the NCH Compliance Department at 847-618-5287. To anonymously report suspected acts of misconduct, contact the NCH Compliance Department at 888-203-2523.