Haven hospice Ongoing fraud case from 8news.org

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Ladies and gentlemenThis post is about the ongoing fraud investigation by 8news.org everyone is considered innocent before be proven guilty in a court of law your discretion is advised

 

 

 

United States Settles False Claims Allegations Against Haven Hospice For More Than $5 Million

Jacksonville, Florida – Acting U.S. Attorney W. Stephen Muldrow announces that Haven Hospice (Haven), a hospice company headquartered in Gainesville, Florida, has agreed to pay $5,085,024 to resolve allegations that Haven violated the False Claims Act by knowingly billing the government for medically unnecessary and undocumented hospice services.

 

The government alleges that Haven knowingly submitted false claims to the Medicare and Medicaid programs for medically unnecessary hospice care for certain patients who had lengths of stays greater than three years. Typically, federal health care programs only pay for hospice care when patients are in a terminal condition and have a life expectancy of less than six months.

 

Since June 1, 2011, Haven treated at least 63 patients with lengths of stay exceeding three years. The government contends that for those 63 patients, Haven either knowingly or recklessly failed to document a valid basis for the initial start of hospice care and/or subsequent hospice coverage. Haven’s diagnoses were not adequately supported, or were supported only with inconsistent practitioner information. Many patients failed to demonstrate objective indications of decline throughout their time in the company’s care, despite some being in hospice for nearly six years. Some patients had their hospice diagnoses changed after several years when they did not show decline under their original “terminal” diagnosis. The government has agreed to accept $5,085,024 to resolve these allegations based on Haven’s ability to pay.

 

“Unfortunately, some healthcare providers seek to defraud Medicare by billing for unnecessary hospice services,” stated Acting U.S. Attorney Muldrow. “Left unchecked, this misconduct would deplete funds available for terminally ill patients desperately in need of the relief that hospice care provides. This settlement should serve as notice to others who consider similar practices that we will vigorously pursue them.”

 

“Charging taxpayers for unnecessary health care services such as hospice care is intolerable,” said Special Agent in Charge Shimon R. Richmond of the U.S. Department of Health and Human Services, Office of Inspector General.  “Working closely with our law enforcement partners, we will vigorously protect the integrity of our Federal health care programs and hold health care companies accountable.”

 

The settlement concludes a lawsuit originally filed in the United States District Court for the Middle District of Florida by a former employee of Haven Hospice, Dr. John Simons. The lawsuit was filed under the qui tam, or whistleblower, provisions of the False Claims Act that permits private individuals to sue on behalf of the government for false claims and to share in any recovery. The Act also allows the government to intervene and take over the action. Dr. Simons will receive roughly $900,000 of the proceeds from the settlement with Haven.

 

The government’s action in this matter illustrates the emphasis on combating health care fraud, and one of the most powerful tools in this effort is the False Claims Act. Tips from all sources about potential fraud, waste, abuse, and mismanagement can be reported to the Department of Health and Human Services, at 800-HHS-TIPS (800-447-8477).

 

This settlement was the result of a coordinated effort by the U.S. Attorney’s Office for the Middle District of Florida, SafeGuard Services LLC (Medicare’s Zone Program Integrity Contractor), and the U.S. Department of Health and Human Services – Office of Inspector General. It was handled by Assistant United States Attorney Shea Gibbons.

 

The case is captioned United States ex rel. Simons v. North Central Florida Hospice, Inc. d/b/a Haven Hospice, Case No. 3:16-cv-330-J-32JRK. The settlement resolves the United States’ claims in that case. The claims resolved by the settlement are allegations only, and there has been no determination of liability.

 

 

 

 

The lying nurse that make you feel off special inside just the past there lies and more to get that good old Medicare dollar

 

 

 

My thoughts on haven hospice and what they’re doing to screw your grandma, grandpa, or loved one

 

 

Haven hospice fraud explained in detail

 

Here is some of the fines in the allegations against haven hospice of Gainesville

North_Central_Florida_Hospice_Inc_dba_Haven_Hospice_12202017 (1)

 

CORPORATE INTEGRITY AGREEMENT
BETWEEN THE
OFFICE OF INSPECTOR GENERAL
OFTHE
DEPARTMENT OF HEALTH AND HUMAN SERVICES
AND
NORTH CENTRAL FLORIDA HOSPICE, INC.
D/B/ A HAVEN HOSPICE
I. PREAMBLE
North Central Florida Hospice, Inc. d/b/a Haven Hospice ( collectively, NCFH)
hereby enters into this Corporate Integrity Agreement (CIA) with the Office ofInspector
General (OIG) ofthe United States Department ofHealth and Human Services (HHS) to
promote compliance with the statutes, regulations, and written directives of Medicare,
Medicaid, and all other Federal health care programs (as defined in 42 U.S.C. § 1320a7b(f)) (Federal health care program requirements). Contemporaneously with this CIA,
NCFH is entering into a Settlement Agreement with the United States.
II. TERM AND SCOPE OF THE CIA
A. The period ofthe compliance obligations assumed by NCFH under this
CIA shall be five years from the effective date ofthis CIA. The “Effective Date” shall be
the date on which the final signatory ofthis CIA executes this CIA. Each one-year
period, beginning with the one-year period following the Effective Date, shall be referred
to as a “Reporting Period.”
B. Sections VII, X, and XI shall expire no later than 120 days after OIG’s
receipt of: (1) NCFH’s final Annual Report or (2) any additional materials submitted by
NCFH pursuant to OIG’s request, whichever is later.
C. For purposes ofthis CIA, the term “Covered Persons” includes: (1) all
owners, officers, directors, and employees ofNCFH; (2) all contractors, subcontractors,
agents, and other persons who furnish patient care items or services or who perform
billing or coding functions on behalf ofNCFH, excluding vendors whose sole connection
with NCFH is selling or otherwise providing medical supplies or equipment to NCFH;
and (3) all physicians and other non-physician practitioners who are members ofNCFH’s
active medical staff.

  1. CORPORATE INTEGRITY OBLIGATIONS

NCFH shall establish and maintain a Compliance Program that includes the following elements:

  1. Compliance Officer and Committee, Board of Directors, and Management Compliance Obligations
    1. Compliance Officer. Within 90 days after the Effective Date, NCFH shall appoint a Compliance Officer and shall maintain a Compliance Officer for the term of the CIA. The Compliance Officer shall be an employee and a member of senior management ofNCFH, shall report directly to the President ofNCFH, and shall not be or be subordinate to the General Counsel or Chief Financial Officer or have any responsibilities that involve acting in any capacity as legal counsel or supervising legal counsel functions for NCFH. The Compliance Officer shall be responsible for, without limitation:
      1. developing and implementing policies, procedures, and practices designed to ensure compliance with the requirements set forth in this CIA and with Federal health care program requirements;
      1. making periodic (at least quarterly) reports regarding compliance matters directly to the Board of Directors of NCFH and shall be authorized to report on such matters to the Board of Directors at any time. Written documentation of the Compliance Officer’s reports to the Board of Directors shall be made available to OIG upon request; and
      1. monitoring the _day-to-day compliance activities engaged in by NCFH as well as any reporting obligations created under this CIA.

Any noncompliance job responsibilities of the Compliance Officer shall be limited and must not interfere with the Compliance Officer’s ability to perform the duties outlined in this CIA.

NCFH shall report to OIG, in writing, any changes in the identity of the Compliance Officer, or any actions or changes that w~mld affect the Compliance

North Central Florida Hospice, Inc. d/bla Haven Hosplce

Corporate Integrity Agreement

2

Officer’s ability to perform the duties necessary to meet the obligations in this CIA, within five days after such a change.

  1. Compliance Committee. Within 90 days after the Effective Date, NCFH shall appoint a Compliance Committee. The Compliance Committee shall, at a minimum, include the Compliance Officer and other members of senior management necessary to meet the requirements of this CIA (~, senior executives of relevant departments, such as billing, clinical, human resources, audit, and operations). The Compliance Officer shall chair the Compliance Committee and the Committee shall support the Compliance Officer in fulfilling his/her responsibilities ~, shall assist in the analysis ofNCFH’s risk areas and shall oversee monitoring of internal and external audits and investigations). The Compliance Committee shall meet at least quarterly. The minutes of the Compliance Committee meetings shall be made available to OIG upon request.

NCFH shall report to OIG, in writing, any actions or changes that would affect the Compliance Committee’s ability to perform the duties necessary to meet the obligations in this CIA, within 15 days after such a change.

  1. Board ofDirectors Compliance Obligations. The Board of Directors (or a committee of the Board) ofNCFH (Board) shall be responsible for the review and oversight of matters related to compliance with Federal health care program requirements and the obligations of this CIA. The Board must include independent (i.e., non-executive) members.

The Board shall, at a minimum, be responsible for the following:

  1. meeting at least quarterly to review and oversee NCFH’s compliance program, including but not limited to the performance of the Compliance Officer and Compliance Committee;
  1. submitting to OIG a description of the documents and other materials it reviewed, as well as any additional steps taken, such as the engagement of an independent advisor or other third party resources, in its oversight of the compliance program and in support of making the resolution below during each Reporting Period; and

North Central Florida Hospice, Inc. dlbla Haven Hospice

Corporate Integrity Agreement

3

  1. for each Reporting Period of the CIA, adopting a resolution, signed by each member of the Board summarizing its review
    • and oversight ofNCFH’s compliance with Federal health care program requirements and the obligations of this CIA.

At minimum, the resolution shall include the following language:

“The Board of Directors has made a reasonable inquiry into the operations ofNCFH’s Compliance Program, including the performance of the Compliance Officer and the Compliance Committee. Based on its inquiry and review, the Board has concluded that, to the best of its knowledge, NCFH has implemented an effective Compliance Program to meet Federal health care program requirements and the obligations of the CIA.”

If the Board is unable to provide such a conclusion in the resolution, the Board shall include in the resolution a written explanation of the reasons why it is unable to provide the conclusion and the steps it is taking to implement an effective Compliance Program at NCFH.

NCFH shall report to OIG, in writing, any changes in the composition of the Board, or any actions or changes that would affect the Board’s ability to perform the duties necessary to meet the obligations in this CIA, within 15 days after such a change.

      1. Management Certifications. In addition to the responsibilities set forth in this CIA for all Covered Persons, certain NCFH employees ( Certifying Employees) are expected to monitor and oversee activities within their areas of authority and shall annually certify that the applicable NCFH department is in compliance with applicable Federal health care program requirements and the obligations of this CIA. These Certifying Employees shall include, at a minimum, the following:
    1. President;
    1. Vice President of Business Development;
    1. Vice President of Clinical Operations;
    1. Vice President of Legislative Affairs;
    1. Chief Financial Officer;
    1. Executive Medical Director(s);
    1. Human Relations Business Partner;
    1. Director of Corporate Compliance and Risk Management;
  1. Compliance Specialist III; and

North Central Florida Hospice, Inc. d/b/a Haven Hospice

Corporate Integrity Agreement

INDEPENDENT REVIEW ORGANIZATION
This Appendix contains the requirements relating to the Independent Review
Organization (IRO) required by Section 111.D ofthe CIA. I
A. IRO Engagement
1. NCFH shall engage an IRO that possesses the qualifications set forth in
Paragraph B, below, to perform the responsibilities in Paragraph C, below. The IRO
shall conduct the review in a professionally independent and objective fashion, as set
forth in Paragraph D. Within 30 days after OIG receives the information identified in
Section V.A.7 ofthe CIA or any additional information submitted by NCFH in response
to a request by OIG, whichever is later, OIG will notify NCFH ifthe IRO is
unacceptable. Absent notification from OIG that the IRO is unacceptable, NCFH may
continue to engage the IRO.
2. IfNCFH engages a new IRO during the term of the CIA, that IRO must
also meet the requirements ofthis Appendix. If a new IRO is engaged, NCFH shall
submit the information identified in Section V.A.7 ofthe CIA to OIG within 30 days of
engagement ofthe IRO. Within 30 days after OIG receives this information or any
additional information submitted by NCFH at the request ofOIG, whichever is later, OIG
will notify NCFH if the IRO is unacceptable. Absent notification from OIG that the IRO
is unacceptable, NCFH may continue to engage the IRO.
B. IRO Qualifications
The IRO shall:
1. assign individuals to conduct the Claims Review who have expertise in the
Medicare and state Medicaid program requirements applicable to the claims being
reviewed;
2. assign individuals to design and select the Claims Review sample who are
knowledgeable about the appropriate statistical sampling techniques;
North Central Florida Hospice, Inc. dlbla Haven Hospice
Corporate Integrity Agreement
30
3. assign individuals to conduct the coding review portions ofthe Claims
Review who have a nationally recognized coding certification and who have maintained
this certification ~, completed applicable continuing education requirements);
4. assign licensed nurses or physicians with relevant education, training and
specialized expertise ( or other licensed health care professionals acting within their scope
ofpractice and specialized expertise) to make the medical necessity determinations
required by the Claims Review; and
5. have sufficient staff and resources to conduct the reviews required by the
CIA on a timely basis.
C. IRO Responsibilities
The IRO shall:
1. perform each Claims Review in accordance with the specific requirements
ofthe CIA;
2. follow all applicable Medicare and state Medicaid program rules and
reimbursement guidelines in making assessments in the Claims Review;
3. request clarification from the appropriate authority (~, Medicare
contractor), if in doubt of the application of a particular Medicare or state Medicaid
program policy or regulation;
4. respond to all OIG inquires in a prompt, objective, and factual manner; and
5. prepare timely, clear, well-written reports that include all the information
required by Appendix B to the CIA.
D. IRO Independence and Objectivity
The IRO must perform the Claims Review in a professionally independent and
objective fashion, as defmed in the most recent Government Auditing Standards issued
by the U.S. Government Accountability Office.
North Central Florida Hospice, Inc. d/b/a Haven Hospice
Corporate Integrity Agreement
31
E. IRO Removal/Termination
1. NCFH and IRO. IfNCFH terminates its IRO or ifthe IRO withdraws from
the engagement during the term ofthe CIA, NCFH must submit a notice explaining (a) its
reasons for termination of the IRO or (b) the IRO’s reasons for its withdrawal to OIG, no
later than 30 days after termination or withdrawal. NCFH must engage a new IRO in
accordance with Paragraph A ofthis Appendix and within 60 days oftermination or
withdrawal ofthe IRO.
2. OJG Removal ofIRO. In the event OIG has reason to believe the IRO does
not possess the qualifications described in Paragraph B, is not independent and objective
as set forth in Paragraph D, or has failed to carry out its responsibilities as described in
Paragraph C, OIG shall notify NCFH in writing regarding OIG’s basis for determining
that the IRO has not met the requirements ofthis Appendix. NCFH shall have 30 days
from the date of OIG’s written notice to provide information regarding the IRO’s
qualifications, independence or performance of its responsibilities in order to resolve the
concerns identified by OIG. If, following OIG’s review of any information provided by
NCFH regarding the IRO, OIG determines that the IRO has not met the requirements of
this Appendix, OIG shall notify NCFH in writing that NCFH shall be required to engage
a new IRO in accordance with Paragraph A ofthis Appendix. NCFH must engage a new
IRO within 60 days of its receipt of OIG’s written notice. The final determination as to
whether or not to require NCFH to engage a new IRO shall be made at the sole discretion
ofOIG.
North Central Florida Hospice, Inc. d/bla Haven Hospice
· Corporate Integrity Agreement
32
APPENDIXB
CLAIMS REVIEW
A. Claims Review. The Claims Review shall consist oftwo components, the
Eligibility Review and the Appropriate Level of Services Review. The IRO shall
perform the Eligibility Review and the Appropriate Level of Services Review annually at
NCFH to cover each ofthe five Reporting Periods.
I. Definitions. For the purposes ofthe Claims Review, the following
definitions shall be used:
a. Overpayment: The amount ofmoney NCFH has received in
excess ofthe amount due and payable under Medicare or any
state Medicaid program requirements, as determined by the
IRO in connection with the reviews performed under this
AppendixB
b. Hospice Population: All hospices owned and/or operated by
NCFH at any time during the Reporting Period. Each NCFH
hospice provider number is to be considered a separate
“Hospice.”
c. Beneficiai:y Population: The Beneficiary Population shall be
defined as all Medicare and state Medicaid program
beneficiaries whose length of stay exceeded 210 days at any
time during the Reporting Period at a Hospice and for whom
NCFH submitted claims and received reimbursement.
d. Claim Period: The period oftime covered by a claim
submitted to Medicare by NCFH for services provided to a
beneficiary.
e. Beneficiary Sample: A Beneficiary Sample shall consist of a
statistically valid random sample of 50 Medicare and state
Medicaid program beneficiaries drawn from the Beneficiary
Population.
North Central Florida Hospice, Inc. d/b/a Haven Hospice
Corporate Integrity Agreement
33
f. Eligibility Review Error Rate: The Eligibility Review Error
Rate shall be calculated by dividing the Overpayment in the
Eligibility Review by the total dollar amount associated with
hospice services reimbursed by Medicare and any state
Medicaid program for beneficiaries in the Beneficiary
Poptdation included in the Eligibility Review.
g. Level of Services: One ofthe four categories of care
reimbursed under the Medicare or state Medicaid program
hospice benefit, which consist of:
1. Routine Home Care – when a patient is at home and is
not receiving Continuous Care services;
11. Continuous Care – when a patient is at home and
receives services that consist predominantly of nursing
care on a continuous basis for brief periods of crisis
and as necessary to maintain the terminally ill at home.
See 42 C.F.R. § 418.204;
111. Inpatient Respite Care – when a patient receives care
at an approved facility on a short term basis for respite;
and
1v. General Inpatient Care – when a patient receives care
in an inpatient facility for pain control or acute or
chronic symptom management that cannot be managed
in other settings.
h. Appropriate Level of Services Review Error Rate: The Error
Rate for the Appropriate Level of Services Review shall be
calculated by dividing the Overpayment in the Appropriate
Level of Services Review by the total dollar amount associated
with hospice services reimbursed by Medicare or any state
Medicaid program for beneficiaries in the Beneficiary
Population included in the Appropriate Level of Services
Review

 

 

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