Office of Institutional Compliance - Standards of Conduct Guide

General Compliance Guidelines

Edward Randall Jr., M.D., attended UTMB and was later appointed to succeed his father as professor of therapeutics in 1928. Also served on the Board of Directors of the Sealy and Smith Foundation.

Q	What are some examples of fraud?
A	Improper billings to third-party payers (government and private insurance payers) for services that were not rendered to a patient. Billing for procedures or services not performed or rendered or with inadequate documentation. Certifying medical necessity for a patient to receive services, when the patient has no medical condition or diagnosis qualifying him or her for the services. Accepting free items or services in exchange for purchasing goods or services or for patient referrals. Lying on an application in order to gain employment. Falsifying any type of records: payroll or time records, medical records, scientific research records. Providing false receipts and documentation for any type of reimbursement from UTMB, e.g. travel
Q	What are some examples of abuse?
A	Ordering and billing for services in excess of what the patient needs. Using sick leave when not sick. Collecting more money than due on expense reimbursements. Taking a long lunch or break without approval. Taking products or supplies belonging to UTMB.

Fraud, waste, and abuse. It is every employee’s responsibility to prevent fraud, waste, and abuse. The University of Texas System Fraud Policy, http://www.utsystem.edu/BPM/50.htm, specifies our individual responsibilities and actions regarding fraud/dishonest acts. The UTMB policy 3.10.1, Discipline and Dismissal, addresses certain fraudulent activities. The policy may be accessed via the Internet at http://www.utmb.edu/policy/ihop/

Fraud is defined as knowingly and willfully attempting to receive financial gain by making false statements or developing a scheme to receive anything of value.

Abuse is defined as activities that result in excessive or unreasonable costs to UTMB, or other state or federal agencies.

Employees who are discovered in any type of fraud or abuse activity will receive disciplinary action, including termination and possible prosecution by state or federal agencies if applicable.

For your protection, you should become familiar with the University of Texas System Fraud Policy, Business Procedure Memorandum 50-06-94. A copy may be obtained from your supervisor, the Human Resources Department or by accessing the web at http://www.utsystem.edu/BPM/50.htm

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General Compliance Guidelines

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