Policy 10—Employees will not knowingly make or present a false, fictitious or fraudulent claim to a Federal agency.
Policy 11—Employees will not use the US Postal Service or electronic submission processes as part of a scheme to defraud the government or obtain money by false or fraudulent pretenses.
Policy 12—Employees will not embezzle, steal or otherwise convert to the benefit of another person or intentionally misapply money, funds, securities, premiums, credits, property or other assets of a health care benefit program.
Policy 13—Employees will not willfully prevent, obstruct, mislead, delay or attempt to prevent, obstruct, mislead or delay the communication of information or records relating to a violation of Federal health care offense to a criminal investigator. Note: Legal Counsel should be contacted immediately upon learning of such investigations.
Policy 14—Employees will not conspire to defraud any government agency or health care benefit program in any manner for any purpose.
False Claims/Whistleblower Suits:
The False Claims Act allows a private person, known as a “relator,” to bring a lawsuit on behalf of the United States, where the private person has information that the named defendant has knowingly submitted or caused the submission of false or fraudulent claims to the United States. The relator need not have been personally harmed by the defendant’s conduct. The False Claims Act has a very detailed process for the filing and pursuit of these claims. For more information on the Whistleblower process, including State and Federal protections in these situations, please see the footnote at the end of this section or the UHS Employee Handbook. A copy of the Employee Handbook can be obtained from the GME Office.
It is the policy that University Health Systems of Eastern Carolina will not take any adverse action or retribution against any employee due to the good faith reporting of a suspected violation or irregularity. We encourage our employees to report any suspected violations of law and to ask questions if they are unsure of a regulation.
COMPLIANCE AT THE BRODY SCHOOL OF MEDICINE
The Brody School of Medicine (BSOM) is committed to providing the highest quality patient care, education and research in an ethical and law abiding manner. The BSOM Office of Compliance is committed to building and maintaining a culture of compliance that encourages faculty, staff, students, and agents to conduct all BSOM operations with honesty and integrity. The BSOM Compliance Program provides a framework for BSOM compliance with applicable healthcare federal and state laws and regulations, and the BSOM Code of Conduct. The Director of Compliance at BSOM is Joan A. Kavuru, J.D., R.N.
Everyone working for or on behalf of BSOM has an obligation to be aware of the rules and regulations that govern their work and an obligation to seek
March 17, 2009