Preventing fraud, waste and abuse
The purpose of Scripps Health Plan’s anti-fraud plan is to establish methods for objectively and systematically evaluating and investigating potential fraud, waste, and/or abuse of Scripps Health Plan delivery system.
Scripps Health Plan strives to continuously improve the structure, processes and outcomes of its anti-fraud activities.
What is fraud
Health care fraud is the intentional misrepresentation for financial gain by an individual, group or entity. Fraud occurs when an individual or entity knows (or should know) that something is false and takes deceptive actions with the intent to receive an unauthorized benefit to themselves or another person.
What is abuse
Abuse includes actions that may result in: unnecessary costs; improper payment; payment for services that fail to meet professionally recognized standards of care; or services that are medically unnecessary. Abuse involves payment for items or services when there is no legal entitlement to that payment and the provider has not knowingly or intentionally misrepresented the facts to obtain payment.
Abuse cannot be differentiated categorically from fraud, because the distinction between “fraud” and “abuse” depends on specific facts and circumstances, intent and prior knowledge, and available evidence, among other factors.
What is waste
Waste within health care means over-utilization (using more than needed) of health care services, or other practices that result in unnecessary costs. Waste is generally not considered to be caused by criminally negligent actions but rather the misuse of resources.
Fraud, waste and abuse within health care is costly for everyone. It leads to higher health care costs and premiums, more uninsured people and fewer dollars available for necessary health care services.
Health care fraud, waste and abuse comes in many forms and requires providers, members and Scripps Health Plan to work together to prevent unnecessary costs. We work closely with our affiliates and are committed to effectively reducing fraudulent activity. The most prevalent examples of misspending that occur in health care today include:
- Falsification of drug prescriptions
- Fabrication and/or falsification of a claim or supporting documentation which impacts the rate of reimbursement, capitation or other payment
- Unbundling of claims for which established payment guidelines those services should be billed as a “bundle” (one payment for multiple services)
- “Up-coding” or “down-coding” of claims or otherwise making a false representation of the clinical severity, complication or other factor impacting the rate of reimbursement
- Use of benefits by non-covered persons (with or without the knowledge of the beneficiary), e.g. use of health plan ID cards by persons who are not entitled to benefits
- Excessive charges for services or supplies above the usual, customary and reasonable charges for those items or services or contrary to an agreed upon contracted rate
- Charges for services which are included in the capitation rate
- Soliciting, offering or receiving a kickback, bribe or other self-benefit, in violation of the Stark Law and anti-kickback regulations (e.g., paying for patient referrals or member assignments)
- Fraud or abuse perpetrated by plan staff and/or contracted network staff for purposes of self-benefit or to improperly compensate or receive compensation from a network provider
If you suspect fraud, waste or abuse, please notify us immediately:
- Scripps Health Plan Compliance Officer - 858-927-5360
- Compliance and Patient AlertLine (confidential and toll-free) - 888-424-2387
You are protected
Scripps Health Plan believes no person should be retaliated against for reporting a concern about potential misconduct. Reporters who wish to be kept anonymous shall be, to the extent practical and permissible by law. Scripps Health Plan does not tolerate threats or actions of retaliation, retribution or other negative acts that would dissuade an individual from reporting potential misconduct. Furthermore, federal “whistleblower” protections shield reporters from retaliation for making a report of potential misconduct in good faith.