Deficit Reduction Act of 2005

1.                  PURPOSE:  To establish guidelines for compliance with Section 6032 of the Deficit Reduction Act of 2005, to furnish information to employees, agents and contractors serving the University of Alabama Health Services Foundation (“UAHSF”) about the provisions of the laws covering false claims submitted for reimbursement under government programs (collectively, the “False Claims Laws”), the associated penalties for violating the False Claims Laws, protections afforded to whistleblowers under the False Claims Laws, and information on UAHSF’s policies and procedures for detecting and preventing fraud, waste and abuse.

2.                  PHILOSOPHY:  UAHSF is committed to the highest standards of ethics, honesty, and integrity in pursuit of its mission of patient care, research and education.  This standard reiterates the commitment of the UAHSF to comply with all applicable federal and state laws and regulations. 

3.                  STANDARDS:

3.1.            All employees, contractors and agents shall be informed of the False Claims Laws described in Exhibit A.

4.                  PROCEDURE:

4.1.            Reporting Suspected Non-compliance with False Claims Laws.  An employee, contractor or agent who discovers or reasonably believes that UAHSF or any UAHSF staff member may be involved in any activity prohibited by the False Claims Laws, or other fraud and abuse laws is required to report such belief to his or her supervisor or normal chain of command; agents and contractors should contact the UAHSF’s employee most directly responsible for the activities from which the concern arises.

4.1.1.      Any supervisor or member of management who receives a report of activity prohibited by the False Claims Laws, or other fraud and abuse laws shall review the facts associated with the report and refer any material concerns to the Corporate Compliance Office for review or consultation.

4.1.2.      If an employee, contractor or agent is uncomfortable speaking with a supervisor or the UAHSF’s employee most directly responsible for the activities for which the concern arises has continuing concerns after having done so, the employee or contractor can seek the assistance of the Compliance Office by calling 205-731-9863.

4.1.3.      If an employee, contractor or agent would like to report the issue or concern anonymously, he or she can call the Corporate Compliance Hotline at 205-801-8080. 

4.1.4.      If callers choose to identify themselves, their confidentiality shall be protected to the extent permitted by law.

4.3.            Policies and Procedures for Detecting and Preventing Fraud, Waste, and Abuse.

4.3.1.      UAHSF Corporate Compliance Program demonstrates UAHSF’s commitment to complying with the law and to ethical conduct by setting forth guidelines designed to prevent and detect violations of law any by providing support, training and educational resources.  This policy is intended to supplement the UAHSF’s existing Corporate Compliance Program Plan, Compliance Handbook, Employee Handbook, and policies by providing specific information to employees, contractors and agents. 

4.3.2.      The Compliance Officer is responsible for the proactive prevention of fraud and abuse through education and training of UAHSF employees and agents.  Similarly, UAHSF employees, contractors and agents always have a responsibility to report concerns about actual or potential wrong-doing and are not permitted to overlook such actual or potential wrong-doing.  UAHSF has several compliance policies and procedures aimed at protecting fraud, waste, and abuse.  Please refer to the UAHSF Compliance website to view these policies.

Whenever a UAHSF employee, contractor or agent has any questions about the possible application of the above laws to any activities, s/he should consult with the Compliance Officer.