Floracare Fraud, Waste, and Abuse Policy

1. Policy Statement 

Floracare is committed to the highest standards of ethical and legal conduct. We have a zero-tolerance policy for fraud, waste, and abuse (FWA) in any form. This policy outlines our expectations, defines key terms, and establishes procedures for detecting, reporting, and responding to FWA related to Consumer Directed Services (CDS) and other Medicaid funded programs. 

2. Definitions 

• Fraud: Any intentional deception or misrepresentation made by a person with the knowledge that the deception could result in some unauthorized benefit to themselves or another person.

Example: Billing for services not rendered falsifying timesheets. 

• Waste: Overutilization of services or misuse of resources not caused by criminal conduct but resulting in unnecessary costs.

Example: Providing more CDS units than medically necessary. 

• Abuse: Provider practices that are inconsistent with sound fiscal, business, or  medical practices and result in unnecessary costs to Medicaid.

Example: Failure to document services appropriately, billing for overlapping services. 

3. Examples of Prohibited Conduct 

• Falsifying timesheets or documentation 
• Clocking in or out for hours not actually worked 
• Caregivers claiming to be present when not with the client 
• Providing services while the client is hospitalized or out of the home
• Accepting or offering kickbacks or incentives to gain or retain clients 
• Failing to disclose known overpayments or errors 

4. Responsibilities 

All Floracare team members must: 

• Act with integrity and accuracy when recording services 
• Immediately report suspected or actual FWA 
• Cooperate with internal investigations and external audits 
• Complete mandatory FWA and HIPAA training annually 

Supervisors and office staff must: 

• Monitor caregiver compliance and timesheet accuracy 
• Investigate any inconsistencies or red flags 
• Take corrective action when violations occur