Fraud, waste, and abuse in the nation’s Medicaid program are estimated to cost taxpayers billions of dollars every year. Vaya Partners is responsible for detecting, preventing, and resolving fraud, waste, and financial abuse of public funds and ensuring all services delivered and claims paid by Vaya Partners are for service delivery and documentation that is in compliance with controlling authority and generally accepted accounting principles.
Report fraud, waste, or abuse online using Vaya Partners’ EthicsPoint compliance portal or call our 24/7 Confidential Compliance (Fraud, Waste, and Abuse) Hotline at 1-866-916-4255.
Fraud is an intentional deception or misrepresentation made by a person with the knowledge that the deception could result in some unauthorized benefit to himself or some other person. It includes any act that constitutes fraud under applicable federal or state law. Examples of provider fraud in the Medicaid program include:
- Billing for services, treatment, or assessments that are not provided, not medically necessary, or that lack documentation
- Committing medical identity theft
- Altering and/or falsifying documentation
- Double-billing, balance billing, upcoding, or other inappropriate billing
- Unbundling services
- Billing for unreasonable or inflated hours
- Falsifying credentials
- Substituting generic drugs
- Billing for more expensive procedures than were performed or unallowable expenditures
- Soliciting or accepting kickbacks
- Submitting false cost reports
- Billing from a non-credentialed or authorized site or for services that the provider or staff are improperly or not licensed to perform
- A member allowing someone else to use their Medicaid card to obtain services
- A member failing to report all of their income or other insurance when applying for Medicaid
Read more: Vaya Partners False Claims Act Notice
Network providers must ensure they do not employ or contract with excluded individuals or entities. You must screen against the Office of Inspector General’s (OIG) List of Excluded Individuals and Entities, available on the OIG’s Exclusion Website.
Waste is defined as misuse, underutilization, or overutilization of items or services. This could also be any other inappropriate or unnecessary billing, as well as medical practices that directly or indirectly add to healthcare costs. This also includes unwarranted or unexplained variations in care that result in no discernible differences in health or member outcomes.
Abuse is defined as provider practices that are inconsistent with sound fiscal, business, or medical practices and result in an unnecessary cost to the Medicaid program, reimbursement for services that are not medically necessary, or those that fail to meet professionally recognized standards for healthcare. It also includes beneficiary practices that result in unnecessary costs to the Medicaid program. Examples include:
- Overutilization of medical and healthcare services
- Separate billing for care and services that are part of an all-inclusive procedure or included in the per diem rate
- Billing for care and services that are provided by an unauthorized or unlicensed person
- Failure to provide and maintain proper quality of care, appropriate care and services, or medically necessary care and services within accepted medical standards for the community
- Breach of the terms and conditions of contracts
- Failure to comply with requirements of certification
- Failure to comply with the provisions for submitting claims for payment
- Failure to comply with controlling authority
All Vaya Partners network providers must monitor and guard against potential fraud, waste, and abuse and must take immediate action to address and report any suspected incidents.
Report by phone or online
Network providers are required to establish a system or mechanism for employees, contractors, and individuals receiving services to report potential fraud, waste, or abuse. Network providers must also establish a system to report potential violations of anti-fraud laws, including, but not limited to, the False Claims Act and anti-kickback statutes.
You must also ensure that your employees, contractors, and individuals receiving services are aware of the following mechanisms to report potential fraud, waste, abuse, or violations of the anti-fraud laws directly to Vaya Partners or other oversight authorities:
- Call Vaya Partners’ 24/7 Confidential Compliance (Fraud, Waste, and Abuse) Hotline at 1-866-916-4255 (allows for anonymous reporting)
- Report online using EthicsPoint (allows for anonymous reporting)
- Call the N.C. Medicaid Fraud, Waste and Program Abuse Tip-Line at 1-877-DMA-TIP1 (1-877-362-8471)
- Call the OIG’s National Fraud Hotline at 1-800-HHS-TIPS (1-800-447-8477) or report to the OIG online
Establish and implement a robust compliance program
The Patient Protection and Affordable Care Act requires all healthcare providers to establish and implement a compliance program. You must develop a formal compliance plan that includes procedures designed to guard against fraud and abuse. For more information and guidance about your compliance responsibilities as a healthcare provider who accepts public funding, please refer to the U.S. Health and Human Services’ OIG Compliance Resources Portal.
Providers can help promote compliance by printing and posting Vaya Partners’ “Your Path to Reporting Fraud, Waste, and Abuse” poster in your office.
Comply with Vaya Partners program integrity reviews, audits and investigations
Vaya Partners’ Special Investigations and Payment Integrity Units conducts announced and unannounced reviews, audits and investigations of Medicaid and non-Medicaid paid claims to identify program abuse, waste, and overpayment(s). It is your responsibility to cooperate with us during these activities.
Conduct self-audits
In addition to reporting potential fraud, waste, and abuse violations, providers must conduct self-audits no less than annually (or more often in response to identification of questionable billing practices or staff ineligibility for billing) per your contract with Vaya Partners. In accordance with federal law, you must return any overpayment you identify within 60 days of identification and notify Vaya Partners of the reason for overpayment in writing.
For more information on conducting your self-audit, please refer to our Provider Self-Audit Protocol for Paid Claims Audits and Provider Self-Audit Overpayment Summary (Excel workbook).