A compliance program sends an important message to employees that mistakes will occur and that employees have an affirmative duty to report those mistakes so that they may be corrected. A compliance plan discourages employees from turning to the government or a payer to resolve issues or, what is worse, to one of the many attorneys advertising on the internet that promise whistleblowers large recoveries.
It is important to educate employees on the differences between "erroneous" and "fraudulent" claims. Some employees may fear that the government will "come down on them" for making mistakes, while others may be overly focused on "doing the right thing" without acknowledging mistakes happen. This difference in perspectives can create differences in opinion that leads to whistleblowers. It is important for employees to understand that the government cannot impose criminal, civil or even administrative penalties for most errors.
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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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