Code of Conduct 2025-01 - Flipbook - Page 25
03 | With Honesty, Transparency, and Extreme Ownership
Fraud, Waste, and Abuse
We are committed to using healthcare resources ethically and
responsibly. Fraud, waste, and abuse don’t just lead to unnecessary
costs — they can also violate the law and put patient care at risk.
Laws like the False Claims Act and the Stark Law, as well as Ivy’s
policies and procedures, help protect our patients from fraud,
waste, and abuse. We all play a role in preventing fraudulent billing,
improper referrals, and the misuse of government healthcare funds.
Get the Terms Right:
What is the Stark Law?
The Stark Law (also known as the Physician Self-Referral
Law) prohibits a physician from making a referral for
“designated health services” to an entity in which they (or
a member of their family) have a financial relationship.
Physical therapy is a designated health service, so referrals
must comply with Stark Law regulations.
How we do the right thing:
Make the Right Call:
Only submit accurate and truthful claims for reimbursement
— never inflate, alter, or falsify billing information.
Fraud, waste, and abuse may not always be obvious — but even
unintentional mistakes can lead to serious consequences.
Ask yourself…
Only bill for services provided and that are
medically necessary.
Avoid referring Medicare or Medicaid patients to entities
in which we (or our family members) have a financial interest,
unless an exception under the Stark Law applies. Contact Legal
for guidance.
Understand that we must follow all applicable laws and
regulations when working with government healthcare
programs to prevent False Claims Act violations.
Am I being asked to bill for services that weren’t actually
provided?
Have I noticed a pattern of medically unnecessary
services or treatments?
Could this referral or financial arrangement be seen
as benefiting me or my family instead of the patient?
Would I feel comfortable explaining this billing decision
to a patient or an auditor?
Report any suspected or actual fraud, waste, and abuse
as soon as possible via the incident reporting process
or the hotline.
Still not sure? Consult Legal and Compliance for guidance.
Fraud, Waste, and Abuse
Ivy Rehab | Code of Conduct
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