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Contractor Vendor Information

The Deficit Reduction Act of 2005 was signed into law by President Bush in February 2006. This law requires that any organization that receives or pays $5 million or more for services provided to Medicaid beneficiaries provide training to its employees, vendors and contractors on the Federal False Claims Act and the Whistle Blower provisions as well as the State false claims act.

Responsibilities

As a contractor or vendor to any Cook Children's Health Care System entity, you are responsible for your employees being knowledgeable concerning the following information:

  • Physicians, hospitals and others (providers) billing Medicaid for services must have documentation in the medical records supporting the bill for those services and must be appropriately licensed to provide the services.
  • Providers must not bill for more services or items than those provided and documented in the medical record.
  • Providers must use the most appropriate codes for billing of services provided.
  • Providers must not bill separately for services or items that are a single service (unbundle).
  • Managed Care Organizations contracted with Medicare/Medicaid to provide services to their beneficiaries must provide services that are required under the contract.
  • If a provider chooses not to obey the rules for billing, the government may consider this fraud and could prosecute the provider under the False Claims Act.
  • Financial penalties are high for filing false claims ($5,500 to $11,000 per claim) plus additional fines and penalties.
  • The False Claims Act(s) protect those who report fraudulent activity, in good faith, under the whistleblower provisions of the act.
  • Whistleblowers are protected under the law from retaliation and also may participate in any financial settlement if the provider is found guilty or settles with the government.
  • If you or any of your employees believe, or have reason to believe, that Cook Children's Health Care System or any of its affiliated entities are not following applicable laws or regulations, you should report that information to the Cook Children's compliance officer as indicated below. The report should be made in good faith. Fraud or abuse means the provider knew something was wrong and chose to do it anyway, versus, a simple error. Either of these situations needs to be corrected.
  • Cook Children's encourages you to report any concern you may have to its Compliance Officer, who can be reached at 682-885-1358 or by email at compliance@cookchildrens.org. You may also report your concerns directly to the United States HHS/OIG or to the Texas HHS/OIG.

Download our Code of Conduct