Vendor Privacy Policy

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.

• Employee Compliance Education
• Preventing and Reporting Fraud

Frequently Asked Questions

Regarding the State of Illinois and Federal False Claims Acts and the Deficit Reduction Act

What is the False Claims 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:

• Charging for tests and procedures never performed
• Performing unnecessary medical procedures in order to increase reimbursement
• Double-charging and billing for tests
• Falsifying time records
• Winning a contract through kickbacks and bribes
• Forging a physician’s signature to gain government reimbursement

Why Do I Need to Know Anything About the False Claims Acts? What is Their Purpose?

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.

What is the Deficit Reduction Act?

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:

• Provide detailed information about the False Claims Acts for all employees of NCH and any contractor or agent of NCH
• Identify administrative remedies for false claims and statements
• Identify any other related federal and state laws pertaining to civil or criminal penalties for false claims and statements
• Explain whistleblower protections under such laws in order to detect fraud, waste and abuse in the federal healthcare programs
• Include the policies and detailed provisions regarding the procedures for detecting and preventing fraud, waste and abuse
• Include in any employee handbook a specific discussion of the laws describing the rights of employees to be protected as whistleblowers and policies and procedures for detecting and preventing fraud, waste and abuse

Steps have been taken to ensure that NCH meets all of these requirements.

What is a Whistleblower?

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.

If I Think There is a Questionable or Unlawful Activity Taking Place, What Should I Do?

Vendors are encouraged to communicate problems, complaints and concerns about suspected unlawful practices.

What Will Happen to Me if I Report a Concern?

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.

Are the DRA and False Claims Acts Only About Medicaid Dollars?

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.

Where Can I Get More Information?

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.