Summary of Fraud and Abuse Reporting Policy

(Information for dissemination)

In accordance with the requirements of the Alabama Medicaid Agency Maternity Care Program, the Gift of Life Maternity Care Program (GOL MCP) has developed a plan for reporting fraud and abuse.  This plan, which is a part of the Quality Assurance Performance Improvement program of the GOL MCP, is in compliance with all mandatory State and Federal guidelines as specified in 42 CFR 38.608 (b)(1), Section 6032 of the Deficit Reduction Act, and Section 1902 (a)(68) of the False Claims Act and whistleblower protections.

Compliance Plan and Procedures:

The GOL MCP, its employees, agents, subcontractors and recipients, shall report, in writing or orally, suspected fraud and abuse to the Alabama Medicaid Agency, either directly or through the GOL MCP.

All reports of suspected fraud and abuse, oral or written, shall be reported to the Alabama Medicaid Agency by Gift of Life within two working days of receipt of the original report. 

The GOL MCP written contracts require providers to cooperate with reporting requirements for suspected fraud and abuse.  Gift of Life Foundation personnel policies require employees to report suspected fraud and abuse.

Gift of Life Foundation shall provide education and training to employees and subcontractors concerning suspected fraud and abuse reporting requirements.  This education and training may take various forms including, but not limited to, the Subcontractor Education Program, the Gift of  Life Newsletters, and dissemination of its written policy either in electronic or paper form or both.  The Suspected Fraud and Abuse reporting plan shall be covered in the Gift of Life Foundation New Employee Orientation and in periodic in-services for all employees.  

The GOL MCP does not tolerate improper conduct by its employees, officers and members, nor the taking of reprisals against those who come forward to disclose such conduct.  In accordance with the false claims act and whistleblower protections, the GOL MCP will take all reasonable steps to protect people who make such disclosures from any detrimental action in reprisals.

The Gift of Life Foundation recognizes the value of transparency and accountability in its administrative and management practices, and supports the reporting of substantial mismanagement of public resources, or conduct involving a substantial risk to public health and safety or the environment.

The Gift of Life Foundation will take all reasonable steps to protect people who make such disclosures from any detrimental action in reprisal for making the disclosure.  It will also afford natural justice to the person who is the subject of the disclosure.

Periodic articles will be placed in the Gift of Life Newsletter for education and reminders to all agents and subcontractors. A quarterly report of all suspected fraud and abuse activity shall be given to the GOL MCP Quality Assurance Committee for review.

For more information about the Gift of Life Fraud and Abuse Policy, contact the Gift of Life Compliance Officer at 334-272-1820.

For more information about Fraud and Abuse with Alabama Medicaid, see "Fraud/Abuse Prevention" subheading on the Alabama Medicaid Agency website, www.medicaid.state.al.us