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Contractor Corporate Compliance

As required by law, Wyoming County Community Health System is advising you of its Corporate Compliance policy Concerning the False Claims Acts, Anti-Retaliation Protections, and Detecting and Responding to Fraud. Congress passed the Deficit Reduction Act Section 6032, which requires certain entities to educate their employees, contractors, and agents about the federal and state false claims statutes and whistleblower protections. Additionally, in 2006, the NYS Legislature enacted Section 363-d of the Social Security Law, requiring all entities participating in Medicaid to establish a program to address the prevention of Medicaid fraud, abuse, and waste.

It is the policy of Wyoming County Community Health System to obey all federal and state laws, to implement and enforce procedures to detect and prevent fraud, waste, and abuse with respect to payments to Wyoming County Community Health System from federal or state healthcare programs, and to provide protections for those who report actual or suspected wrongdoing. All employees, including management and any contractors or agents, are educated in accordance with the law regarding the federal and state false claims statutes and their role in preventing and detecting fraud, waste, and abuse in federal health care programs.

Wyoming County Community Health System takes issues regarding false claims and fraud and abuse seriously. We are committed to providing an environment of honesty, integrity, and trust. All employees, management, and contractors or agents of Wyoming County Community Health System are made aware of the laws regarding fraud and abuse and false claims and are encouraged to identify and report concerns. Any individual with a concern is encouraged to discuss the situation with Wyoming County Community Health System’s Corporate Compliance Officer, another member of management, or with the Corporate Compliance Hotline at 585-786-2233 extension 4899.Failure to report known violations, failure to detect violations due to negligence or reckless conduct is punishable to civil penalties. All employees, managers, and contractors are encouraged to report Fraud, Abuse, and False Claims to the Corporate Compliance Office of Wyoming County Community Health System. In addition, the Office of Medicaid Inspector General (OMIG) has a website with a toll-free hotline that makes it easy for whistleblowers to file a complaint.

I would like to advise you that you may contact the Corporate Compliance Office at 585-786-2233 extension 4899 for any questions regarding the attached policy and to discuss any potential violations. Thank you for your attention to this important matter.

Sincerely,

Margaret Cunningham, RN, MS, ANP-C
Wyoming County Community Health System
Corporate Compliance Officer



Definition of “Contractor” or “Agent”
Any contractor, subcontractor, agent, or other person which or who, on behalf of the entity, furnishes, or otherwise authorizes the furnishing of Medicaid health care items or services, performs billing or coding functions or is involved in monitoring health care provided by the entity.