In the last few years, the federal government has made it known that it will go into all health care institutions and physician practices to look for violations of billing, coding, or other regulations associated with Medicare and Medicaid. Since each billing mistake is considered an error or fraudulent activity, a hospital or physician practice can be fined multiple times. Whether or not there was ever an intent to defraud the federal government is not an issue presently.
Intentions play no role in defining a mistake as a fraudulent act.
We plan to establish a process whereby any mistakes found can be immediately reported, preferably within one's own organization to one's supervisor. But we will also have safeguards in place to allow individuals to report errors or suspected mistakes to members of senior administration, to Barbara Briggs or myself, or through an anonymous hotline, if that is preferred. We want to protect our employees from any kind of retaliation or discrimination if they find and report an error, even if they are involved in one. But obviously, we cannot protect employees who knowingly and fraudulently commit acts that are illegal. In cases where someone has knowingly and purposefully done something that is illegal, appropriate disciplinary action will have to be taken.