The Deficit Reduction Act applies to employees, associates, vendors, providers and any other business partner, vendor, contractor, client, and the community of The Arc of Union County. The Arc of Union County, Inc. is committed to complying with the requirements of the Federal Deficit Reduction Act (DRA) of 2005 and to preventing and detecting fraud, waste, and abuse. The DRA requires The Arc of Union County to establish written policies regarding compliance with the federal False Claims Act and certain other laws, which include whistleblower protections and procedures for detecting and protecting against fraud, waste and abuse, as a condition of receiving reimbursement from federal and state health care programs.

False Claims Act (FCA)

As a recipient of Medicaid federal health care program funds, The Arc of Union County is required by law to include in its policies and provide to all employees, associates, agents and contractors, detailed information regarding the federal False Claims Act. This includes applicable state civil and criminal laws intended to prevent and detect fraud, waste, and abuse in federal health care programs.

As an employee, associate, vendor, provider and any other business associate of The Arc of Union County, you are required to adhere to The Arc of Union County’s  Fraud, Waste and Abuse and the Federal False Claims Act Policy. Please ensure that all applicable personnel within your organization understand and agree to follow The Arc of Union County’s Fraud Waste and Abuse Policy when engaging in activities related to their work with The Arc of Union County. Under the False Claims Act, it is a violation to knowingly submit a false claim to the federal government.

Examples of health care fraud that could lead to the submission of false claims to the government are:

• Falsifying billing or medical coding
• Billing for goods or services not medically necessary
• Duplicate billing for items or services
• Submitting bills for services never performed or items never furnished.
• Failing to return overpayments.

The Arc of Union County’s Code of Conduct and Ethical Behavior emphasizes honesty and integrity. All members of The Ac of Union County’s community, including vendors, associates and business partners, must comply with federal, state, and local laws and must exercise their duty to prevent fraud, waste and abuse at The Arc of Union County. Such duties include, but are not limited to, reporting all concerns and suspicions regarding instances of fraud, waste, abuse, or suspected false claims act violations to appropriate parties or authorities.

The Arc of Union County maintains a corporate compliance program and strives to educate all members of the The Arc of Union County’s community on fraud and abuse laws, including the importance of submitting accurate claims and reports to federal and state governmental authorities. Anyone with knowledge of potential fraud, waste, or abuse must report such through any of the following methods:

1. Vendors, Contractors and the Community can contact the Arc of Union Compliance Hotline: instructions to report a concern: Dial:  (973) 315-0046 or internal staff can dial extension 2046 from an agency phone  or  *67 (973) 315-0046 form any phone other than their agency phones And or send an e-mail to: CorporateCompliance@arcunion.org
2. Send electronic mail to:  The Arc of Union County’s compliance staff, Susan Luckman, Associate Executive Director, Quality, Compliance and Planning at SLuckman@arcunion.org (973) 315.0070 or Human Resources, Carolyn Scott, Associate Executive Director, Chief of Staff, CScott@arcunion.org (973) 315.0008.
3. Call the toll-free NJ Fraud and Abuse Hotline at 1-888-9FRAUD5 (1-888-937- 2835) and report any information about fraud, waste or abuse in Medicaid or NJ Family Care. Callers can either speak to the hotline operator or leave a message if the operator does not answer. Callers do not have to give their name and may receive a reward if their call leads to a recovery. Also, contact the NJ Insurance Fraud Prosecutor Hotline: 877-55-FRAUD
4. Call the toll-free hotline established by the Federal Office of Inspector General in the U.S. Department of Health and Human Services to report any fraud, waste or abuse involving Medicare or any other health care program involving only federal funds. That hotline number is 1-800-HHS-TIPS (1-800-447-8477). For more information about this hotline and about other ways to contact the Office of Inspector General, you can go to https://oig.hhs.gov/fraud/report-fraud/

Retaliation or retribution for reporting issues in good faith is strictly prohibited and enforced at The Arc of Union County.