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Fraud, Waste and Abuse in Ohio

Compliance is everyone’s responsibility at Molina. We support honest communication, safety and trust in line with our Code of Business Conduct and Ethics.

Fraud Prevention Tips

Molina Healthcare of Ohio (Molina) seeks to uphold the highest ethical standards for the provision of health care benefits and services to its members and supports the efforts of federal and state authorities in their enforcement of prohibitions of fraudulent practices by providers or other entities dealing with the provision of health care services.

Definitions

Abuse: means provider practices that are inconsistent with sound fiscal, business, or medical practices, and result in unnecessary costs to state and federal health care programs, or in reimbursement for services that are not medically necessary or that fail to meet professionally recognized standards for health care. It also includes recipient practices that result in unnecessary cost to state and federal health care programs. (42 CFR § 455.2).

Conviction or Convicted: means that a judgment of conviction has been entered by a federal, state or local court, regardless of whether an appeal from that judgment is pending (42 CFR 455.2). This definition also includes the definition of the term “convicted” in Welfare and Institutions Code Section 14043.1 (f).

Fraud: means an intentional deception or misrepresentation made by a person with the knowledge that the deception could result in some unauthorized benefit to themself or some other person. It includes any act that constitutes fraud under applicable federal or state Law. (42 CFR § 455.2).

Health Care Fraud: includes but is not limited to the making of intentional false statements, misrepresentations or deliberate omissions of material facts from any record, bill, claim or any other form for the purpose of obtaining payment, compensation or reimbursement for health care services.

Waste: means health care spending that can be eliminated without reducing the quality of care. Quality waste includes overuse, underuse and ineffective use. Inefficiency waste includes redundancy, delays and unnecessary process complexity. An example would be the attempt to obtain reimbursement for items or services where there was no intent to deceive or misrepresent, however the outcome of poor or inefficient billing methods (e.g. coding) causes unnecessary costs to state and federal health care programs.

Federal False Claims Act, 31 USC Section 3279

The False Claims Act is a federal statute that covers fraud involving any federally funded contract or program, including the Medicare and Medicaid programs. The Act establishes liability for any person who knowingly presents or causes to be presented a false or fraudulent claim to the U.S. government for payment.

The term "knowingly" is defined to mean that a person with respect to information:

  • Has actual knowledge of falsity of information in the claim;
  • Acts in deliberate ignorance of the truth or falsity of the information in a claim; or
  • Acts in reckless disregard of the truth or falsity of the information in a claim.

The Act does not require proof of a specific intent to defraud the U.S. government. Instead, health care providers can be prosecuted for a wide variety of conduct that leads to the submission of fraudulent claims to the government, such as knowingly making false statements, falsifying records, double billing for items or services, submitting bills for services never performed or items never furnished or otherwise causing a false claim to be submitted.

Examples of Fraud, Waste, and Abuse

By a member

By a provider

Lending an ID card to someone who is not entitled to it

Billing for services, procedures and/or supplies that have not actually been rendered

Altering the quantity or number of refills on a prescription

Providing services to patients that are not medically necessary

Making false statements to receive medical or pharmacy services

Balancing billing a Medicaid member for Medicaid covered services

Using someone else's insurance card

Double billing or improper coding of medical claims

Including misleading information on or omitting information from an application for health care coverage or intentionally giving incorrect information to receive benefits

Intentional misrepresentation of manipulating the benefits payable for services, procedures and or supplies, dates on which services and/or treatments were rendered, medical record of service, condition treated or diagnosed, charges or reimbursement, identity of provider/practitioner or the recipient of services, "unbundling" of procedures, non-covered treatments to receive payment, "upcoding" and billing for services not provided

Pretending to be someone else to receive services

Concealing patients misuse of Molina Health card

Falsifying claims

Failure to report a patient's forgery/alteration of a prescription

Other Provider Crimes

  • Knowingly and willfully soliciting or receiving payment of kickbacks or bribes in exchange for the referral of Medicare or Medicaid patients
  • Knowingly and willfully referring Medicare or Medicaid patients to health care facilities in which or with which the physician has a financial relationship (The Stark Law)
  • Balance billing: asking the patient to pay the difference between the discounted fees, negotiated fees and the provider's usual and customary fees

Preventing Fraud and Abuse

Healthcare fraud is rising every year. Molina and other state and federal agencies are working together to help prevent fraud. Please see your Provider Manual for additional examples of fraud, waste and abuse and ways to prevent it.

Reporting Fraud and Abuse

You may report suspected cases of fraud and abuse to Molina Healthcare's Compliance Officer. You have the right to have your concerns reported anonymously to Molina Healthcare and/or United States Office of Inspector General.

When reporting an issue, please provide as much information as possible.

The more information provided the better the chance the situation will be successfully reviewed and resolved.

Remember to include the following information when reporting suspected fraud or abuse:

  • Nature of complaint
  • Names of individuals and/or entity involved in suspected fraud and/or abuse, including address, phone number, Medicaid ID number and any other identifying information.

You may report fraud and abuse to Molina Healthcare through the Molina Healthcare AlertLine available 24 hours a day, 7 days a week, 365 days a year.

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