Dear Valued Contractor or Agent of Princeton HealthCare System:
The Deficit Reduction Act (DRA) of 2005 mandates that effective
January 1, 2007, Princeton HealthCare System (PHCS) as a healthcare
provider receiving annual payments under the State Medicaid plan of at
least $5 million must:
Establish written policies for all employees of the entity (including
management), and of any contractor or agent of the entity, that provide
detailed information about the False Claims Act (FCA) and any State laws
pertaining to civil or criminal penalties for false claims and
statements, and whistleblower protections under such laws, with respect
to the role of such laws in preventing and detecting fraud, waste, and
abuse in federal health care programs.
Include as part of such written policies, detailed provisions regarding
the entity’s policies and procedures for detecting and preventing
fraud, waste and abuse.
Princeton HealthCare System supports the efforts of federal and state
authorities in identifying incidents of fraud and abuse and has the
necessary procedures in place to prevent, detect, report and correct
incidents of fraud and abuse in accordance with contractual, regulatory
and statutory requirements.
As a contractor or agent of PHCS, we are notifying you of the PHCS False
Claims Act Policy, which sets forth the guidelines that all employees,
contractors and agents are required to follow to assure compliance with
the FCA and to detect and prevent fraud, waste and abuse. Please
disseminate this letter and make the PHCS FCA policy available to all of
your employees who provide services to PHCS.
Under the FCA, it is a violation to knowingly submit a false claim to
the government. All employees, contractors or agents with knowledge of
potential fraud and abuse situations must report such situations through
either of the following methods:
Contacting the PHCS Chief Compliance Officer/Corporate Compliance Office directly at 609-853-7140 or
Calling the confidential PHCS Compliance Hotline at 1-800-779-4035.
Retaliation or retribution for reporting issues “in good faith” is prohibited at PHCS.
Below please find some examples of Health Care Fraud that may lead to the submission of fraudulent claims to the government:
Falsifying billing and/or medical coding records;
Billing for services not medically necessary;
Duplicate billing for items or services;
Submitting bills for services never performed or items never furnished;
Failing to report overpayments.
If you have any questions about this policy, contact Nancy Fletcher,
PHCS Compliance and Privacy Officer, at 609.853.7140. To download our FCA policy, click here.