Sample Medicare Fraud Policy

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					         g. In those instances where Division of Inspector
            General believes it to be in the best interests of the                                                    FRAUD, WASTE AND
            investigative audit, Division of Inspector General
            has the authority and duty, after consulting with
                                                                                                                        ABUSE POLICY
            the Clerk of the Circuit Court, as applicable, to:                                                              OFFICE OF THE CLERK
            1) take control/limit employee access, and/or                                                                  OF THE CIRCUIT COURT
               gain full access to all Pinellas County premises
               utilized by the Clerk of the Circuit Court,
               whether owned or rented, and
            2) examine, copy and/or remove all or any                                                   
               portion of the contents of any document.

    8.1 Great care must be taken in the investigative audit
        of suspected improprieties or irregularities so as to
        avoid mistaken accusations or alerting suspected
        individuals that an investigative audit is under way.
        a. All inquiries from suspected individuals and their
            attorneys or representatives should be directed
            to Division of Inspector General. Proper response        Public Integrity Unit
            to such an inquiry is: “I am not at liberty to discuss   Division of Inspector General
            this matter.”                                            Fraud Hotline
        b. Under no circumstances should any reference be            510 Bay Avenue
            made to “what you did,” “the crime,” “the fraud,”        Clearwater, FL 33756
            “the forgery,” “the misappropriation” or any other
            specific reference.
        c. No promises should be made.
                                                                     Fraud Hotline
   8.2   Management/employees should not contact the
                                                                     Phone: (727) 453-3728
         suspected individual in an effort to determine facts
         or demand restitution.                                      Fax: (727) 464-8386
   8.3   Management/employees are encouraged not to
         discuss the case, facts, suspicions or allegations with     E-mail:
         anyone outside the organization or those within the
         organization who do not have a legitimate need to
         know unless specifically asked to do so by Division of      Internet:
         Inspector General or law enforcement.
   8.4   Management/employees are required to cooperate                                                            An independent service offered by the Clerk of the
         with the investigative audit process through                                                                Circuit Court of Pinellas County. The Division of
         answering questions, furnishing of written            
                                                                                                                    Inspector General assists the Clerk in fulfilling an
         statements, volunteering information important to
                                                                                                                  oversight responsibility as well as in finding methods
         the investigative audit, etc.
                                                                                                                      to enhance county government operations.
   8.5   All Clerk of the Circuit Court departments/employees         These contacts may also be used
         are required to comply with this policy.
                                                                     to report cases involving fraud or
9.	 LIMITATION                                                            waste of a ward’s assets.
    Nothing in this directive or policy shall be construed to
    interfere with, limit, restrict or otherwise impair the Clerk
                                                                                                                          Ken Burke, CPA
    of the Circuit Court’s or any official’s ability to manage,                                                     Clerk Of The Circuit Court
    train, assign or discipline their employees.                                                          03/11      Pinellas County, Florida
1.	 POLICY                                                            4.2   Waste refers to the unnecessary incurring of costs as     7.2   A current or former Pinellas County employee who
    The Pinellas County Clerk of the Circuit Court’s Fraud,                 a result of inefficient practices, systems or controls.         suspects fraud, waste or abuse, and wishes to remain
    Waste and Abuse Policy and Procedures are established                                                                                   anonymous, should:
                                                                      4.3   Abuse refers to violations and circumventions of
    to facilitate the development of internal controls that                                                                                 a. Contact the Fraud Hotline and provide as much
                                                                            departmental or agency regulations which impair
    will provide for the detection, prevention and reporting                                                                                   detailed information as possible regarding the
                                                                            the effective and efficient execution of operations.
    of fraud, waste and abuse directed against county                                                                                          suspected fraudulent conduct.
    government. It is the intent of this policy to promote
    awareness of the potential for fraud, waste and abuse          5.	 INVESTIGATIVE	AUDIT	RESPONSIBILITIES                                 b. The caller, though anonymous, must be willing to
    throughout the county government, and to provide                   5.1 The Clerk of the Circuit Court, Division of Inspector               share specific information regarding the suspected
    guidelines and assign responsibility for the development               General has the primary responsibility for investiga-               fraudulent conduct.
    of adequate internal controls and systems.                             tive audits of all suspected inappropriate activity        7.3   A member of the public suspecting fraud, waste or
                                                                           as defined in this policy. If the investigative audit            abuse, is encouraged to contact the Fraud Hotline
   It is the policy of the Pinellas County Clerk of the Circuit            substantiates that a fraudulent act has occurred,
   Court to ensure compliance with the principles of right                                                                                  with specific and detailed information regarding the
                                                                           Division of Inspector General will notify the Clerk              suspected fraudulent conduct.
   and wrong which govern the conduct of county                            of the Circuit Court, or Pinellas County Administra-
   employees, vendors, consultants, contractors and all                    tor as applicable, and such other County officials as      7.4   A supervisor or higher authority receiving a fraud
   other outside agencies/parties doing business with                      appropriate. If the substantiated fraudulent act has             allegation should:
   Pinellas County. This policy is intended to communicate                 criminal implications, Division of Inspector General             a. Compile all information relayed by the reporting
   the Clerk of the Circuit Court’s desire to eliminate                    will consult with law enforcement agencies as nec-                  individual.
   unethical practices while creating an environment in                    essary to assist in the preparation and presentation
   which employees and/or citizens are encouraged and                                                                                       b. Contact Division of Inspector General with all
                                                                           of criminal findings in a court of law.                             compiled information.
   comfortable in the reporting of fraud, waste or abuse.
                                                                      5.2   Division of Inspector General, through authorization            c. Cooperate with the investigative audit process.
   The law in Florida protects employees from retaliatory
   or adverse personnel action for disclosing certain                       of the Clerk of the Circuit Court, is hereby authorized
                                                                                                                                      7.5   Division of Inspector General will:
   information, including, but not limited to, violations of                to make investigative audits into Pinellas County
                                                                            affairs and for that purpose may administer oaths               a. Maintain a Fraud, Waste and Abuse Hotline, and
   laws which create and present a substantial and specific
                                                                            and compel the production of books, papers and                     attempt to secure as much information as possible
   danger to the public’s health, safety or welfare and
                                                                            other evidence material to said inquiry.                           from the reporting individual.
   suspected acts of gross mismanagement or gross waste
   of public funds. These protections are detailed in Sections                                                                              b. Contact law enforcement, as appropriate in the
   112.3187-112.31895 of the Florida Statutes.                     6.	 CONFIDENTIALITY                                                         circumstances, and provide fraud, waste and
                                                                       Division of Inspector General treats all information                    abuse information for consideration as to their
2.	 PURPOSE                                                            received confidentially, to the extent allowed by law.                  involvement in the case.
    This directive provides instruction and guidance for               Any employee, citizen, contractor, vendor or other                   c. Evaluate reported conduct pertaining to any and
    implementing the Fraud, Waste and Abuse Policy                     interested party who has observed or suspects dishonest                 all departments of Pinellas County and such other
    adopted by the Clerk of the Circuit Court.                         or fraudulent activity should notify the Fraud Hotline                  activities/entities engaged in the expenditure of
                                                                       immediately. Persons observing or suspecting dishonest                  county funds.
3.	 SCOPE                                                              or fraudulent activity should not attempt to personally
    This directive is applicable to all Pinellas County Clerk of       conduct an investigation related to such activity.                   d. Report investigative audit findings to the County
    the Circuit Court employees.                                                                                                               Administrator or Clerk of the Circuit Court, as
                                                                                                                                               applicable, in an interim report. If interim findings
                                                                   7.	 PROCEDURES
4.	 DEFINITIONS                                                                                                                                are of a countywide nature or are otherwise
                                                                       7.1 A current or former Pinellas County employee who
    4.1 Fraud refers to, but is not limited to, any dishonest                                                                                  significant, the Board of County Commissioners
                                                                           suspects fraud, waste or abuse, and does not desire
        or fraudulent act to include forgery or alteration                                                                                     may also be notified if any of their personnel are
                                                                           anonymity, should:
        of any document; misappropriation of funds,                                                                                            involved.
        supplies, etc.; improper handling or reporting of                   a. Report the suspected fraud to the Fraud Hotline.             e. Report any significant findings to the County
        money or financial transactions; profiting by self or               b. If requested, furnish a detailed written statement,             Administrator, Clerk of the Circuit Court and Board
        others as a result of inside knowledge; destruction                    under oath, outlining the suspected fraud.                      of County Commissioners, as applicable, in a final
        or intentional disappearance of records, furniture,                                                                                    report.
        fixtures or equipment; accepting or seeking anything                c. Cooperate with the investigative audit process
                                                                               through the furnishing of written statements,                f. Work with law enforcement authorities as
        of material value from vendors or persons providing                                                                                    determined necessary during the course of the
        services or materials to Pinellas County for personal                  interviews, etc.
                                                                                                                                               investigative audit and refer applicable findings to
        benefit; and/or any similar or related irregularity.                                                                                   appropriate authorities upon completion.

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