Compliance: Federal and state false claims acts

We've updated our corporate compliance program policies and procedures as mandated by the federal Deficit Reduction Act of 2005 (the “DRA”). The new policy, Federal and State False Claims Acts, summarizes federal and Massachusetts laws aimed at fraud, waste, and abuse in health care programs and is applicable to all FCHP employees, contractors and agents who provide services for FCHP’s Medicaid HMO or Summit ElderCare’s PACE program and their beneficiaries. 

The Centers for Medicare and Medicaid Services (CMS) requires FCHP to “establish and disseminate [this policy] which must also be adopted by its contractors or agents.” The CMS guidance broadly defines “contractor or agent” to mean “any contractor, subcontractor, agent or other person which or who, on behalf of the entity, furnishes, or otherwise authorizes the furnishing of Medicaid health care items or services, performs billing or coding functions, or is involved in monitoring of health care provided by the entity.” As such, we are furnishing this policy for your adoption.

If you have any questions regarding the new policy, please contact Anne Doyle, Senior Vice President and Chief Compliance Officer.

View the Federal and State False Claims Acts policy