Corporate Compliance

Code of Ethics/Conduct: 
Please take a moment to read the attached procedure "Code of Ethics/Conduct"
When you are done, click the back button, or come back to this quiz and finish the rest of the questions.

https://progressindustries.org:8080/__policies/Code%20of%20Ethics.docx

Healthcare Fraud, Waste and Abuse Procedure:
Please take a moment to read through the attached procedure "Healthcare Fraud, Waste and Abuse." When you are done, click the back button, or come back to this quiz and finish the rest of the questions. 

https://progressindustries.org:8080/__policies/Healthcare%20Fraud,%20Waste%20&%20%20Abuse%20Policy.docx


1) What does Corporate Compliance mean? 'Corporate' can be considered the same as organizational. 'Compliance' means following the rules of a third party. Corporate Compliance includes the actions Progress Industries must take to meet the expectations of the U.S. Sentencing Guidelines from the Federal Sentencing Reform Act of 1984. Overall, it means actions, policies, procedures, reviews, audits, prevention strategies, corrective actions, modifications, staff training efforts, and reporting systems that are used to prevent and detect illegal or unethical activity and/or fraud, waste and abuse. To help meet these standards, Progress Industries has established a Code Of Ethics/Conduct policy and a Healthcare Fraud, Waste and Abuse policy. You are responsible for becoming familiar with these policies.

The Code of Ethics/Conduct describes what behavior is expected from employees, volunteers, board members, persons served and anyone associated with Progress Industries. It is not an all inclusive list, but gives some guidelines you should keep in mind as you perform your job duties.

Question 1: Corporate Compliance includes only the reporting systems that are used to prevent unethical activity.

Why is corporate compliance requirement a concern for me? Progress Industries receives funding from Medicaid for our ICF/ID, HCBS, and Habilitation services. Additionally, some members receive Medicare funding for their health care and prescriptions. The government is serious about making sure the services they are billed for were performed and submitted accurately. Progress Industries must take steps to prevent, report and correct any conditions that make it possible for healthcare fraud, waste and/or abuse to happen. Every employee in our agency is responsible for preventing and reporting suspected or potential healthcare fraud, waste and abuse.

Question 2: Only managers and members of the Corporate Compliance Team are responsible for reporting healthcare fraud, waste or abuse.

We are already mandatory reporters, why do we have corporate compliance too? Mandatory Reporters are required to report suspected cases of child or dependent adult abuse. Corporate Compliance looks at all other aspects of our business for fraud, waste and abuse. Progress Industries' Corporate Compliance Team will supplement our current processes, but does not change the way you report suspected child or dependent adult abuse.

Question 3: Corporate Compliance looks at many aspects of our business for fraud, waste and abuse, but does not change the way you report suspected cases of dependent adult abuse.

What is P.I. doing about Corporate Compliance?
The Board of Directors has approved a Corporate Compliance Program. A Corporate Compliance Officer has been designated, who will monitor the program and provide periodic reports to the Board on information about the program. The Corporate Compliance Officer is also the chair for our Corporate Compliance Team, which is developing, implementing and monitoring all internal and external auditing, investigative and reporting processes, procedures and systems, and preparing and submitting reports to the CEO and Board of Directors, at least annually. In addition, the Corporate Compliance Team will schedule, coordinate and monitor regular and periodic reviews of risk areas by competent persons external to the organization.

The benefits of Corporate Compliance are:
* Prompts early detection of any violations before they become too serious.
* Identifies problems before they are found by an outside audit or survey.
* Less likely that a violation will keep happening.
* Provides management with a different and accurate view of the organization.
* Reduced fines and penalties in the event of a judgment against the company.
* Limits the liability for employees and managers (fines and/or confinement).

Question 4: Corporate Compliance only benefits the company by fixing problems identified by outside audits.

What is considered healthcare fraud, waste, and/or abuse?

Fraud is knowingly and willfully executing, or attempting to execute, a scheme to defraud any health care benefit program, or to obtain, by means of false or fraudulent pretenses, representations, or promises, any of the money or property owned by, or under the custody or control of, any health care benefit program. In other words, fraud is intentionally submitting false information to the Government or a Government contractor to get money or a benefit. Health care fraud is punishable by imprisonment for up to 10 years. It is also subject to criminal fines of up to $250,000.

Waste includes overusing services, or other practices that, directly or indirectly, result in unnecessary costs. Waste is generally not considered to be caused by criminally negligent actions but rather by the misuse of resources.

Abuse includes actions that may, directly or indirectly, result in unnecessary costs. Abuse involves payment for items or services when there is not legal entitlement to that payment and the provider has not knowingly and/or intentionally misrepresented facts to obtain payment.

Fraud, waste and abuse can include (but is not limited to):
- Billing for services that were never provided.
- False cost reports-expenses not related to services provided are included.
- Illegal kickbacks where providers may conspire with another provider to share monetary reimbursement received in exchange for service referrals. (This could include cash, vacation trips, automobiles or other items of value.)
- Improper payments for Medicaid services, which can include:
*Payment for services when service provision is not adequately documented
*Medically unnecessary services due to a lack of documentation in medical record to support eligibility and need for service
*Incorrect coding when billing for services, using the wrong code for a particular service
*Non-covered costs or services that do not meet the state of Iowa's reimbursement rules and regulations.
*Third-Party liability, where a private insurance company or another payer was the primary payer and Medicaid was
billed instead.

Examples of healthcare fraud you might encounter in your work are:
1) turning hours in for billing that were not worked
2) logging one activity when a different one was actually done
3) working with the person served on activities not covered by their annual plan.

Question 5: If my service documentation does not accurately reflect what a person served and I worked on during service delivery time it could be considered healthcare fraud, waste or abuse.

In order to detect and prevent healthcare fraud, waste and/or abuse, Progress Industries is doing the following:

*We have external audits of financial statements completed by an outside CPA firm for all Medicaid funded services
and another outside CPA firm completes all Medicaid annual cost reports.
*Member of management review intervention notes.
*Training on detecting and preventing healthcare fraud, waste and abuse is provided to all employees.
*QA staff complete random reviews of samples of intervention notes throughout services.
*Management will review, on a quarterly basis, a sample of records to document that the dates of services provided
coincide with billed interventions, accurately reflecting the services that were provided.
*Corrective actions will be identified as a result of these reviews.

Question 6: Only management staff will receive training on detecting and preventing healthcare fraud, waste and/or abuse.

If I suspect something is just slightly wrong, do I need to report it? Absolutely! Progress Industries has a zero tolerance policy for healthcare fraud, waste and abuse. If you suspect any kind of healthcare fraud, waste or abuse, you should report it immediately to the Corporate Compliance Officer. An internal investigation will be initiated, with appropriate actions taken as a result of the findings.

I think there is some fraud/waste/abuse going on in my department. What do I need to do? You need to share your concerns as soon as possible with the Corporate Compliance Officer. The easiest way to reach them is by using our Corporate Compliance Hotline at

641-275-3233. You can also send an e-mail to scott.miller@progressindustries.org. In addition to reporting your concern to the Corporate Compliance Officer, you can utilize the addresses and phone numbers on the company policy Healthcare Fraud, Waste and Abuse.

Question 7: The easiest way to reach the Corporate Compliance Officer is by using the Corporate Compliance Hotline.

What if I report my supervisor and they get mad at me? Progress Industries has a no reprisal reporting system. This means that you will not be punished because you reported what you reasonably believed to be an act of wrong doing or a violation of this program or the company code of ethics/conduct. We protect your privacy by providing a hotline for you to report suspected violations from anywhere and at any time of the day. If you feel you are being retaliated against for reporting healthcare fraud, waste or abuse, you should immediately report this concern to the CEO or Corporate Compliance Officer. The False Claims Act issued by the federal government also provides protection for "whistleblower employees" from retaliation by their employer.

Question 8: You can not be punished simply for making a report of wrong-doing to the Corporate Compliance Officer.

Will you tell anyone that I am the person who reported suspected fraud, waste or abuse? We will make a good faith effort to protect your confidentiality, but we cannot promise that in every case we will be able to do so.
If I turn someone in, am I going to get in trouble? If you have not done anything wrong, you will not be punished simply for reporting suspected fraud. However, if your report includes admissions of personal wrong doing, we cannot guarantee you will be protected from disciplinary action. When determining what, if any, disciplinary action (up to and including termination) may be taken, we will take your honesty into consideration.

Question 9: I turned something in to the Corporate Compliance Team. I will not get in any trouble, even if I admit I did something wrong.

What happens if I suspect healthcare fraud, waste or abuse and don't report it? Your position requires participation in the Corporate Compliance Program. Failure to comply with the requirements of the program will result in discipline, up to and including termination.

What if I have a complaint about the Corporate Compliance Officer? Please direct those complaints to the President/CEO.
For additional training and information on healthcare fraud, waste and abuse, I may visit

https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNGenInfo/index.html
or
www.logisticare.com/drive-with-logisticare

Question 10: If I don't report suspected healthcare fraud, waste or abuse my employment could be terminated.

By submitting my quiz, I am attesting that I have read and understand the Code of Ethics/Conduct procedure and the Healthcare Fraud, Waste and Abuse procedure.