Trilogy Health Services

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General Compliance Standards and Procedures False Claims Act

Reference(s): 31 U.S.C. 3729-3733


1. Fraud: An intentional (willful or purposeful) deception or misrepresentation made by a person with the knowledge that the deception could result in some unauthorized benefit to him/herself or some other person. It includes any act that constitutes fraud under applicable Federal or State law. 2. False Claims Act: The provisions under the FCA state that it is a violation to: a. Knowingly present or cause to be submitted a false claim to the government. 1. For purposes of this section, the terms “knowledge” and “knowingly” mean that a person, with respect to information- a. has actual knowledge of the information; b. acts in deliberate ignorance of the truth or falsity of the information, or c. acts in reckless disregard of the truth or falsity of the information and no proof of specific intent to defraud is required. b. Knowing use of a false record or statement to obtain payment on a false claim paid by the government. c. Engage in a conspiracy to defraud the government by the improper submission of a false claim for payment. d. Damages and penalties for violating the FCA may include: e. Civil penalties of not less than $5,500 and not more than $11,000 per violation, plus f. Three times the amount of damages which the government sustains because of the violation. 3. Qui Tam Provisions (whistleblower rights): The provision of the FCA allows a person to bring an action under the Act on behalf of the federal government and share in the recovery. 4. Retaliation or retribution for reporting issues “in good faith” is prohibited.