TeamHealth, Inc. Compliance Policy

Team Health, Inc.
Compliance Policy

Subject: Federal and State False Claims Act Education Policy for Associates of TeamHealth

Effective Date
 Revision Date
 Review Date
 Policy Number
 1/1/2007    11/16/06  EC008
   01/26/09  01/26/09  
   01/01/10  01/01/10  
     01/25/12  

                                                                                                                                                                                                                 

I.    Purpose:

As an entity that makes or receives Medicaid payment in excess of $5,000,000 per year, TeamHealth must ensure that employees, contractors and other agents (collectively “Associates”) receive appropriate and balanced information relating to federal and state False Claims Act provisions and whistleblower protections under the same. The purpose of this policy is to establish specific written policies and procedures to inform Associates about certain federal and state false claims and whistleblower laws in compliance with the requirements of the Deficit Reduction Act of 2006.

II.    Policy: TeamHealth’s policy to inform all Associates about whistleblower laws that protect employees who identify false claims submitted to the federal and/or state governments from retribution by employers and provide such employees with the ability to pursue financial recoveries on behalf of the government, sharing in the recovery, if successful.  Specific state's laws may be found at http://www.taf.org/states-false-claims-acts. Specifically, the written policies and procedures and/or other written notices provided to Associates will provide information on the following laws, including the role of such laws in preventing and detecting fraud, waste and abuse in federal health care programs:
    
1.    The federal False Claims Act;
2.    Federal administrative remedies for false claims and statements;
3.    State laws pertaining to civil or criminal penalties for false claims and statements; and
4.    Whistleblower protection and recovery provisions under applicable  federal and state laws.

TeamHealth will further notify its Associates in writing that it will never discharge, demote, suspend, threaten, harass, deny promotion to, or in any other manner discriminate against Associates in the terms or conditions of their relationship with TeamHealth due to their  disclosing information to a government or law enforcement agency or in furthering   a claim, including investigation for, initiation of, testimony for, or assistance in a claim filed or to be filed under any federal or state False Claims Act.  

 

III.    Implementation:


1.    Effective January 1, 2007, TeamHealth’s Employee Handbook shall include a section entitled “False Claims Act”, which will provide Associates of TeamHealth who are employees with information on federal and state False Claims Act laws and whistleblower protections under such laws, including the role of such laws in preventing and detecting fraud, waste and abuse in federal health care programs. TeamHealth’s  Employee Handbook shall include: (a) a specific discussion of applicable fraud and abuse laws, (b) the rights of employees who are whistleblowers to be protected from retaliation, and (c) TeamHealth’s policies and procedures for detecting and preventing fraud, waste, and abuse.  All present and future employees of TeamHealth shall be required to provide a written acknowledgment of receipt of the TeamHealth Employee Handbook containing the False Claims Act provision.

2.     Effective January 1, 2007, TeamHealth shall provide written notice to all Associates of TeamHealth who are non-employees containing information on federal and state False Claims Act laws and whistleblower protections under such laws, including the role of such laws in preventing and detecting fraud, waste and abuse in federal health care programs. The written notice shall include: (a) a specific discussion of applicable fraud and abuse laws, (b) the rights of whistleblowers to be protected from retaliation, and (c) TeamHealth’s procedures for detecting and preventing fraud, waste, and abuse.  Such written notices shall be provided to present and future contractors and other non-employees of TeamHealth in a manner that ensures their receipt of the information.