The Harris Health System Code of Conduct maintains strict compliance with applicable laws and regulations. This page contains important information concerning current laws and regulations associated with the Harris Health Vendor Compliance Program.
Deficit Reduction Act of 2005
Requires entities that receive or make annual payments of at least $5 million under a state Medicaid program to establish written policies for employees and contractors who provide detailed information about the Federal False Claims Act (FCA), administrative remedies, any state laws pertaining to civil or criminal penalties for false claims and statements, and whistleblower protections under such laws to prevent and detect fraud, waste and abuse in Federal healthcare programs.
Federal and State False Claims Acts
It is a violation of federal and Texas laws to knowingly submit claims for payment with false and untrue information.
Both Federal and Texas False Claims Acts contain qui tam provisions to protect whistleblowers:
• Any person who reports an allegedly false claim to the federal or state government or participates in their investigation is protected by these acts;
• Includes a prohibition on termination, demotion, suspension, threats, harassment and discrimination; and
• Retaliation also is not permitted.
It is a criminal offense to offer, pay, solicit or receive any remuneration to induce or reward referrals of items or services reimbursable by a federal healthcare program.
The Stark Law prohibits a physician (or an immediate family member of such physician) who has a financial relationship (including compensation and investment /ownership interests) with an entity from referring patients to the entity for certain health services covered by the Medicare program, unless an exception is available.
Health Insurance Portability and Accountability Act (HIPAA)
Provides for portability of health insurance and establishes standards for privacy and security of patient information.
Fraud and Enforcement Recovery Act of 2009 (FERA)
Expands exposure under the False Claims Act (FCA) by imposing liability for:
• Making statements to a private entity, such as a subcontractor that results in payments of federal funds.
• Retaining money owed to the government such as an obligation to refund overpayments.
FERA also expands protection of whistleblowers, permits sharing and use of information between the government, state and local law enforcement agencies and the whistleblowers, and expands the statute of limitations for FCA actions.
American Recovery and Reinvestment Act of 2009 (ARRA), including the HITECH Act
The American Recovery and Reinvestment Act of 2009 (ARRA) and the Health Information Technology for Economic and Clinical Health (HITECH) Act of 2009 make HIPAA's privacy and security standards more stringent and important for healthcare providers and their employees.
It is everyone's duty to report any suspected violations of the law or Harris Health's Code of Conduct.
To report suspected violations of laws, regulations or policies:
Call the Harris Health System Corporate Compliance Officer at 713-566-6461.
Call the confidential Compliance Hotline at 1-800-500-0333 (the hotline is the only method that ensures your anonymity).
It is Harris Health policy that no disciplinary action or retaliation be taken against anyone for reporting a perceived issue, problem, concern or violation to management, Human Resources, Corporate Compliance, The Joint Commission or the Compliance Hotline in good faith pursuant to the Federal False Claims Act, State False Claims Act or other law.
Should you desire additional information about the Harris Health Compliance Program, please see the following links:
Code of Conduct
General Compliance Training Presentation - 2011
Policy #3.31, Fraud, Waste and Abuse
Policy #3.25, Reporting Fraud, Abuse, or Wrongdoing and Non-Retaliation