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Fraud, Abuse, and Whistle blowing

Fraud, Abuse, and Whistle blowing

Financial Policies

Introduction:

Home Health Care Agencies are affected by theft and embezzlement. In addition, any staff member who provides services to a client for deals with client billing or client admission must be educated concerning theft and embezzlement. There is also the problem of employee theft.

Purpose:

The Agency has the responsibility to minimize the opportunity for theft in its client dealings, notify appropriate authorities when theft does occur, and notify and assist individuals who may be the victims of theft. Further, the Agency has the same responsibilities if it has reason to believe that personal information relating to Protected Health Information (PHI) or patient personal information is compromised.

The policy of this agency is that if any staff member becomes aware of the possibility of theft or embezzlement, it is quickly brought to the attention of the Administrator so that an investigation can take place. If the results of the investigation warrant it, action will be taken by applicable laws. It is further the policy of the Agency to ensure that each of its staff members is adequately trained so that they can readily recognize incidents of possible theft or embezzlement.

Procedure:

When a staff member becomes aware of a possible situation of theft or embezzlement

  1. Immediately report it to a supervisor/manager.
  2. If a client of the Agency is the potential victim of the theft, the supervisor/manager will advise the client and advise the client that they will be contacted by another agency representative.
  3. The supervisor/manager, preferably, together with the staff member will report the incident to the Administrator.
  4. An incident report addressed to the Administrator will be prepared as quickly as possible and in no evidence later than 24 hours after the event. The report will include:
    • If the incident involved the possible compromise of PHI held by the Agency:
      • The names and contact information of all individuals who may have had their Personal Information or PHI compromised or unwittingly passed to an unauthorized person
      • The reasons that led the staff member to believe that PHI and or Personal Information may have been compromised
      • A detailed description of the circumstances of the event
    • In the evidence that the incident involved an attempt by a person to make fraudulent use of information belonging to another person:
      • The name and contact information of the potential victim of theft
      • A description of the attempt to defraud and if known, the extent of any potential monetary damages
      • The information that was being used in the attempt to defraud
      • A description of the incident itself and what led to its detection
      • The results of initial contact with the potential victim
      • Safeguards that had been taken (or had not been taken) to protect the potential victim’s information
  1. The Administrator will keep one copy of the incident in a dedicated file and another in the client’s record.
  2. The Administrator will decide based on the evidence presented as to whether or not suspicion was warranted, and the incident could be potentially one of theft.
  3. If the Administrator determines that there is the potential that identity theft exists, the appropriate law enforcement will be notified within 48 hours.
  4. Whether or not the Administrator concludes that there is a potential for theft, he/she will contact the potential victim within 48 hours and explain the situation and the potential victim’s rights. If the Administrator has decided that there is no need to contact law enforcement, but the potential victim feels otherwise, then Law Enforcement will be contacted as above.
  5. If the incident involves the compromise of PHI or Personal Information held by the Agency, the Administrator will, if deemed appropriate after a review of the evidence presented:
    • Contact Law Enforcement
    • Create a task force to contact every client whose personal information may have been compromised
    • Investigate as to the scope of the problem that created the incident and the duration of the problem
    • Notify the Agency’s insurance carrier

Prevention of Theft and Embezzlement

In an attempt to eliminate theft and embezzlement, the Agency will:

    1. Prescreen employees
    2. Conduct frequent physical inventories
    3. Separate bookkeeping functions
    4. Personally approve bookkeeping adjustments
    5. Control check signers
    6. Review monthly bank statements
    7. Tighten up on petty cash