Ethical Billing Practices

Billing Practices
University Health Care providers and facilities charge for services in accordance with billing policies, only to the extent that the services for which charges are being initiated:

1. were actually rendered to the patient and were medically appropriate;
2. were rendered by a medical professional with an appropriate license;
3. are supported with complete and accurate documentation in the medical record;
4. were accurately coded based on current payer and government standards;
5. were billed in accordance with the terms of the third party contract, if applicable; and
6. will be retained for the period of law required by law and University policy.

Reporting of Inappropriate Conduct
University Health Care employees should promptly report known or suspected inappropriate conduct or non-compliant practices to their departmental manager and/or to the Compliance Office at (801) 213-3948 or to the Compliance Hotline at (888)206-6025. In addition, federal and state laws permit employees to raise their concerns with an outside regulatory agency if they believe that University Health Care is not adequately resolving the concern internally.

Protection Against Retaliation (Protection for Whistle-Blowers)
It is forbidden for any employee to harass or retaliate against any employee who, in good faith, has reported a suspected violation of the law or University Health Care policy. Not only is it against University Health Care policy to retaliate against those who report concerns, it is also illegal under both state and federal law. Any employee who violates the non-retaliation policy may be subject to discipline, up to and including termination of employment.

Federal False Claims Act
It is illegal under the federal False Claims Act and a violation of University Health Care policy to submit a claim for property or services that were not provided, or to submit a false claim that includes or is supported by any written statement which is false or omits a fact that the person has a duty to include. It is also a violation of University Health Care policy and the law for any person to make or submit a statement that the person knows or has reason to know is false or omits a fact that the person has a duty to include, which results in a false claim.

Penalties
When a false claim or statement is detected, violators may be subject to legal action in addition to discipline under relevant University of Utah Policies and Procedures. Government penalties may include fines up to $5,000 for each statement and between $5,000 - $10,000 for each claim. The violator may also be required to pay for the damages suffered by the government, and the government could initiate administrative or contractual action against the person as authorized by law, including suspension or debarment from entering into contracts with the federal government.

Utah Laws
In addition to the federal False Claims Act, there is a Utah False Claims Act. This Utah law makes it illegal to submit a false statement or false claim in order to receive a medical benefit or payment for a medical benefit. False claims and false statements include misrepresentations, omissions of key facts, and other deceitful statements and claims. Criminal penalties, up to a second-degree felony, may be imposed upon violators; violators may also be required to make full and complete restitution to the state for all medical benefits and payments improperly obtained, to pay enforcement costs, and to pay civil penalties. Utah law also contains a whistleblower protection statute which prohibits employers from retaliating against employees who raise, in good faith, concerns about the waste of public funds or about the violation or suspected violation of law. Violators may be subject to civil fines and penalties.

Detecting and Preventing Fraud
University Health Care strives, and it expects, that its employees will do everything they can to prevent and detect false claims and potentially fraudulent behavior. The following are examples of measures that University Health Care takes to accomplish this:

• providing staff training;
• investigating reports of potential violations from staff;
• investigating complaints regarding potential violations from patients, family members and friends, and visitors;
• internally monitoring higher risk areas;
• performing internal audits;
• protecting employees who report potential fraud or abuse;
• performing internal risk assessments; and
• corresponding with state and federal agencies regarding potential concerns.

More Information
If you have questions about billing, contact your departmental manager or the University Health Care Compliance Office. If have reason to believe that improper billing is occurring, immediately alert your supervisor or a higher-level manager. In addition, you may contact the Compliance Office at (801) 213-3948 or the Compliance Hotline at (888)206-6025.

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