It is essential that our Steward Health Choice Generations HMO SNP Providers understand what Medicare Fraud, Waste, and Abuse (FWA) is and how to detect it.
The definition of Fraud is the intentional deception or misrepresentation that an individual knows, or should know, to be false, or does not believe to be true, and makes, knowing the deception could result in some unauthorized benefit to himself or some other person(s).
The definition of Waste is the unintentional misuse of Medicare funds through inadvertent error, most frequently incorrect coding and billing.
The definition of Abuse is the reimbursement for services that are not medically necessary or that fail to meet professionally recognized standards for healthcare. Practices that are inconsistent with sound fiscal, business, or medical practices and result in an unnecessary cost to the health plan.
Types of FWA
- Claim FWA: Alteration of claims, Up-coding, Incorrect coding, Double billing, Unbundling, Billing for services not provided, Submission of false documents, Billing non-covered services as covered
- Member FWA; Identity theft, Prescription altering, Doctor shopping, Prescription stockpiling, Misrepresentation of eligibility or medical condition
- False Claims Act – 31 U.S.C. 3729-3733
- Anti-Kickback Statute – 41 U.S.C.
- HIPAA – 45 CFR Title II, 201-250
- Deficit Reduction Act – Public Law 109-171,6032
- Whistleblower Employee Protection Act – 31 U.S.C. 3730(h)
- Stark Law – Social Security Act 1877
Subcontractors are protected from retaliation under 31 U.S.C. 3730(h) for False Claims Act complaints. Health Choice encourages the reporting of suspected FWA confidentially and without fear of retaliation. Zero-tolerance policy for retaliation or retribution against anyone who reports suspected misconduct
Penalties for FWA
It is a federal crime to defraud the government of any of its programs. Individuals who commit fraud may be imprisoned, fined, or both. Criminal convictions typically include restitution and fines. Convictions may also result in being excluded from the Medicare program for a length of time.
Reporting Suspicious Activity
- Report suspicious or potential FWA to Steward Health Choice Generations through your Provider Representative
- Call the Steward AlertLine (any event, any product) at: 1-877-898-6080
- Email the Steward Health Choice Generations Medicare Compliance Department at : HCH.MedicareCompliance@steward.org
- Contact the OIG directly at 1-800-447-8477
- Include all information that supports the potential misconduct
For more information on reporting FWA:Subcontractor Reporting Guide
You may also complete the Fraud, Waste and Abuse Referral form and Mail, Fax, or Email referral to:
Medicare Compliance-Steward Health Choice Generations
410 N 44th Street, Suite 943
Phoenix, AZ 85008
FAX: 480-784-2933 (Attn: Medicare Compliance)