Common use of Fraud and Abuse Program Clause in Contracts

Fraud and Abuse Program. In addition to the specific requirements of OAC rule 5101:3-26-06, MCPs must have a program that includes administrative and management arrangements or procedures, including a mandatory compliance plan, to guard against fraud and abuse. The MCP’s compliance plan must designate staff responsibility for administering the plan and include clear goals, milestones or objectives, measurements, key dates for achieving identified outcomes, and explain how the MCP will determine the compliance plan’s effectiveness. In addition to the requirements in OAC rule 5101:3-26-06, the MCP’s compliance program which safeguards against fraud and abuse must, at a minimum, specifically address the following: a. Employee education about false claims recovery: In order to comply with Section 6032 of the Deficit Reduction Act of 2005 MCPs must, as a condition of receiving Medicaid payment, do the following: i. establish and make readily available to all employees, including the MCP’s management, the following written policies regarding false claims recovery: a. detailed information about the federal False Claims Act and other state and federal laws related to the prevention and detection of fraud, waste, and abuse, including administrative remedies for false claims and statements as well as civil or criminal penalties; b. the MCP’s policies and procedures for detecting and preventing fraud, waste, and abuse; and c. the laws governing the rights of employees to be protected as whistleblowers. ii. include in any employee handbook the required written policies regarding false claims recovery; iii. establish written policies for any MCP contractors and agents that provide detailed information about the federal False Claims Act and other state and federal laws related to the prevention and detection of fraud, waste, and abuse, including administrative remedies for false claims and statements as well as Appendix I Aged, Blind or Disabled (ABD) population Page 2 civil or criminal penalties; the laws governing the rights of employees to be protected as whistleblowers; and the MCP’s policies and procedures for detecting and preventing fraud, waste, and abuse. MCPs must make such information readily available to their subcontractors; and iv. disseminate the required written policies to all contractors and agents, who must abide by those written policies.

Fraud and Abuse Program. In addition to the specific requirements of OAC rule 5101:3-26-06, MCPs must have a program that includes administrative and management arrangements or procedures, including a mandatory compliance plan, plan to guard against fraud and abuse. The MCP’s compliance plan must designate staff responsibility for administering the plan and include clear goals, milestones or objectives, measurements, key dates for achieving identified outcomes, and explain how the MCP will determine the compliance plan’s effectiveness. In addition to the requirements in OAC rule 5101:3-26-06, the MCP’s compliance program complianceprogram which safeguards against fraud and abuse must, at a minimum, specifically address specificallyaddress the following: a. Employee education about false claims recovery: In order to comply with Section 6032 of the Deficit Reduction Act of 2005 MCPs must, as a condition of receiving Medicaid payment, do the following: i. establish and make readily available to all employees, including the MCPtheMCP’s management, the following written policies regarding false claims recoveryclaimsrecovery: a. detailed information about the federal False Claims Act and other state and federal laws related to the prevention and detection of fraud, waste, and abuse, including administrative remedies for false claims and statements as well as civil or criminal penalties; b. the MCP’s policies and procedures for detecting and preventing fraud, waste, and abuse; and c. the laws governing the rights of employees to be protected as whistleblowers. ii. include in any employee handbook the required written policies regarding false regardingfalse claims recovery; iii. establish written policies for any MCP contractors and agents that provide detailed information about the federal False Claims Act and other state and federal laws related to the prevention and detection of fraud, waste, and abuse, including administrative remedies for false claims and statements as well as Appendix I Aged, Blind or Disabled (ABD) population Page 2 civil or criminal penalties,; the laws governing the rights of employees to be protected as whistleblowers; and the MCP’s policies and procedures for detecting and preventing fraud, waste, and abuse. MCPs must make such information readily available to their subcontractors; and iv. disseminate the required written policies to all contractors and agents, who must abide by those written policies. b. Monitoring for fraud and abuse The MCP’s program which safeguards against fraud and abuse must specifically address the MCP’s prevention, detection, investigation, and reporting strategies in at least the following areas: i. Embezzlement and theft – MCPs must monitor activities on an ongoing basis to prevent and detect activities involving embezzlement and theft (e.g., by staff, providers, contractors, etc.) and respond promptly to such violations.

Fraud and Abuse Program. In addition to the specific requirements of OAC rule 5101:3-26-06, MCPs must have a program that includes administrative and management arrangements or procedures, including a mandatory compliance plan, plan to guard against fraud and abuse. The MCP’s compliance plan must designate staff responsibility for administering the plan and include clear goals, milestones or objectives, measurements, key dates for achieving identified outcomes, and explain how the MCP will determine the compliance plan’s effectiveness. In addition to the requirements in OAC rule 5101:3-26-06, the MCP’s compliance program which safeguards against fraud and abuse must, at a minimum, specifically address the following: a. Employee education about false claims recovery: In order to comply with Section 6032 of the Deficit Reduction Act of 2005 MCPs must, as a condition of receiving Medicaid paymentparticipation, do the following: i. establish and make readily available to all employees, including employees through the MCP’s management, employee handbook the following written policies materials regarding false claims recovery: a. policies that provide detailed information about the federal False Claims Act and other state and federal laws related to the prevention and detection of fraud, waste, and abuse, including administrative remedies for false claims and statements as well as civil or criminal penalties; b. the MCP’s policies and procedures for detecting and preventing fraud, waste, and abuse; and c. the laws governing the rights of employees to be protected as whistleblowers. ii. include in any employee handbook the required written policies regarding false claims recovery; iii. establish written policies for any MCP contractors and agents subcontractors that provide detailed information about the federal False Claims Act and other state and federal laws related to the prevention and detection of fraud, waste, and abuse, including administrative remedies for false claims and statements as well as Appendix I Aged, Blind or Disabled (ABD) population Page 2 civil or criminal penalties; the laws governing the rights of employees to be protected as whistleblowers; , and the MCP’s policies and procedures for detecting and preventing fraud, waste, and abuse. MCPs must make such information readily available to their subcontractors; and. Appendix I iv. disseminate b. Monitoring for fraud and abuse: The MCP’s program which safeguards against fraud and abuse must specifically address the required written policies MCP’s prevention, detection, investigation, and reporting strategies in at least the following areas: i. Embezzlement and theft – MCPs must monitor activities on an ongoing basis to all contractors prevent and agentsdetect activities involving embezzlement and theft (e.g., who must abide by those written policiesstaff, providers, contractors, etc.) and respond promptly to such violations.

Fraud and Abuse Program. In addition to the specific requirements of OAC rule 5101:3-26-06, MCPs must have a program that includes administrative and management arrangements or procedures, including a mandatory compliance plan, plan to guard against fraud and abuse. The MCP’s compliance plan must designate staff responsibility for administering the plan and include clear goals, milestones or objectives, measurements, key dates for achieving identified outcomes, and explain how the MCP will determine the compliance plan’s effectiveness. In addition to the requirements in OAC rule 5101:3-26-06, the MCP’s compliance program which safeguards against fraud and abuse must, at a minimum, specifically address the following: a. Employee education about false claims recovery: In order to comply with Section 6032 of the Deficit Reduction Act of 2005 MCPs must, as a condition of receiving Medicaid payment, do the following: i. establish and make readily available to all employees, including the MCP’s management, the following written policies regarding false claims recovery: a. detailed information about the federal False Claims Act and other state and federal laws related to the prevention and detection of fraud, waste, and abuse, including administrative remedies for false claims and statements as well as civil or criminal penalties; b. the MCP’s policies and procedures for detecting and preventing fraud, waste, and abuse; and c. the laws governing the rights of employees to be protected as whistleblowers. ii. include in any employee handbook the required written policies regarding false claims recovery; iii. establish written policies for any MCP contractors and agents that provide detailed information about the federal False Claims Act and other state and federal laws related to the prevention and detection of fraud, waste, and abuse, including administrative remedies for false claims and statements as well as Appendix I Aged, Blind or Disabled (ABD) population Page 2 civil or criminal penalties,; the laws governing the rights of employees to be protected as whistleblowers; and the MCP’s policies and procedures for detecting and preventing fraud, waste, and abuse. MCPs must make such information readily available to their subcontractors; and iv. disseminate the required written policies to all contractors and agents, who must abide by those written policies. b. Monitoring for fraud and abuse The MCP’s program which safeguards against fraud and abuse must specifically address the MCP’s prevention, detection, investigation, and reporting strategies in at least the following areas: i. Embezzlement and theft – MCPs must monitor activities on an ongoing basis to prevent and detect activities involving embezzlement and theft (e.g., by staff, providers, contractors, etc.) and respond promptly to such violations.