Fraud, Waste and Abuse (FWA)
Most doctors work ethically, providing high-quality medical care, and submit proper claims for payment.
Federal and state governments place a great amount of trust in physicians. Medicare, Medicaid and other government health care programs rely on physicians’ medical judgment to treat patients with appropriate services. When reimbursing physicians, hospitals, labs, and durable medical equipment suppliers for services provided to program patients, the federal government relies on physicians to submit accurate and truthful information.
Unfortunately, some dishonest health care providers who exploit the health care system for illegal personal gain has created the need for laws that combat fraud and abuse and ensure appropriate quality medical care. Some of those laws are listed below:
- Anti-Kickback Statute (42 USC § 1320a-7b(b))
- Stark Law (42 USC § 1395nn)
- Federal False Claims Act 31 (U.S.C. §§ 3729 – 3733)
The Centers for Medicare and Medicaid Services (CMS) helps physicians understand how to comply with federal laws by identifying "red flags" that could lead to potential liability in law enforcement and administrative actions. For more information, read Avoiding Medicare Fraud & Abuse: A Roadmap for Physicians.
Protecting your medical practice against health care fraud is important too. CMS provides training on safeguarding your medical identity.
Contacting and Reporting to Compliance
Memorial Hermann Health Solutions, Inc. has adopted processes to receive, record and respond to compliance questions, reports of potential or actual non-compliance, and Fraud, Waste and Abuse (FWA) from employees, contractors, vendors, providers and members. Memorial Hermann Health Solutions, Inc. maintains confidentiality to the extent possible, allows anonymity if desired, and ensures non-retaliation against those who report suspected misconduct in good faith.
Memorial Hermann Corporate Compliance and Ethics Hotline:
- 713-338-4140 or 1-877-448-4140
- Para ayuda en Español: 800-297-8592
You may contact us in writing at:
Memorial Hermann Health Solutions, Inc.
929 Gessner Rd. Suite 1500
Houston, TX 77024
Or you may submit reports of potential or actual non-compliance to us through this online form.
If you have questions or need guidance from Health Solutions' Compliance here are some ways you can reach us:
Reference Materials for Part D FWA
Quick Reference Guide for Pharmacists: Includes a list of top controlled and non-controlled drugs being abused, signs of fraud and suspect behavior to be on the lookout for.
Recommended Pharmacy Action Plan: A guide on how to Preserve Program Integrity and Help Fight Medicare Parts C and D Fraud.