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Angeles Health Center

Angeles Health Center is committed to conducting its operations in compliance with ethical standards, contractual obligations under State and Federal programs, laws, and regulations applicable to Medicare and Medi-Cal.​

CODE OF BUSINESS CONDUCT AND ETHICS 

We adopt IEHP Code of Business Conduct and Ethics Policy at www.IEHP.org

Code of Business Conduct and Ethics (iehp.org)

COMPLIANCE, FRAUD, WASTE, AND ABUSE (FWA), AND PRIVACY TRAINING PROGRAM

We adopt IEHP Compliance, Fraud, Waste, and Abuse (FWA), and Privacy Program Training Policy at www.IEHP.org​

It is our commitment to:

Prevent, detect, and report compliance concerns and potential FWA;
Protect Member’s Protected Health Information (PHI); and
Conduct business in an ethical and professional manner.

We require training all employees within 90 days of hire/start date, and annually thereafter.

EXCLUSION SCREENING

Angeles Health Center has implemented a screening process to identify individuals and entities that appear on the Office of Inspector General (OIG) List of Excluded Individuals and Entities (LEIE), the General Services Administration (GSA) System for Award Management (SAM), the CMS Preclusion List, and the DHCS Medi-Cal Suspended and Ineligible Provider List prior to appointment, contracting, and/or employment and monthly thereafter to ensure that none of these individuals or entities are excluded, ineligible or terminated from participation in State and Federal health care programs.

Delegated Subcontractors must implement a screening program for employees, Board Members, contractors, and business partners to avoid relationships with individuals and/or entities that tend toward inappropriate conduct.

This program includes but is not limited to:

Prior to contract and monthly thereafter, review of the OIG LEIE, GSA SAM, DHCS Medi-Cal Suspended and Ineligible list, to identify individuals and entities that are excluded from participation in government health care programs (42 CFR §10011901).
A monthly review of the DHCS Medi-Cal Suspended and Ineligible Provider List.
Criminal record checks when appropriate or as required by law.
Review of the National Practitioner Databank (NPDB).
Review of professional license status for sanctions and/or adverse actions.
Reporting results to Compliance Committees as necessary.

FRAUD, WASTE, AND ABUSE PREVENTION

Fraud is knowingly and willfully executing, or attempting to execute, a scheme or artifice to defraud any health care benefit program, or to obtain, by means of false or fraudulent pretenses, representations, or promises, any of the money or property owned by, or under the custody or control of, any health care benefit program.

Examples include:

Knowingly billing for services or prescriptions not furnished or supplies not provided
Knowingly altering claim forms for a higher payment
Selling medicine, medical equipment, or other things received through IEHP

Waste includes overuse of services, or other practices that, directly or indirectly, result in unnecessary costs. Waste is generally not considered to be caused by criminally negligent actions but rather by the misuse of resources.

Examples include:

Conducting excessive office visits
Writing excessive prescriptions or ordering excessive tests
Prescribing more medications than necessary for the treatment of a specific condition

Abuse includes actions that may, directly or indirectly, 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 and/or intentionally misrepresented facts to obtain payment.
 
Examples include:

Billing for unnecessary medical services or medical equipment
Billing for brand name drugs when generics are dispensed
Misusing codes on a claim, such as upcoding and unbundling codes.

Report potential FWA or suspicious circumstances as they arise

PRIVACY INCIDENT/BREACH

Angeles Health Center has established a HIPAA Privacy Program to ensure that Member’s health information is properly protected while allowing the flow of health information needed to provide and promote high-quality health care.

A privacy breach is defined as unauthorized acquisition, access, use, or disclosure of protected health information (PHI) which compromises the security or privacy of the PHI.
 
PHI includes individually identifiable health information, including demographic information, whether oral or recorded in any form, that relates to the physical or mental health of a Member, the provision of health care to that Member, or the payment for the provision of health care to that Member.

This generally means that a breach occurs when PHI is accessed, used, or disclosed to an individual or entity that does not have a business reason to know that information. The law does allow information to be accessed, used, or disclosed when it is related to treatment, payment, or healthcare operations directly associated with the work that we do at our clinic on behalf of our Members.

INCIDENT REPORTING INFORMATION AND RECORDS MANAGEMENT

Angeles Health Center has the following policy for reporting issues related to fraud, waste or abuse, privacy, and  Code of Business Conduct & Ethics:

1. Angeles Health Center mandates reporting and non-retaliation for reporting Fraud, Waste and Abuse, non-compliance, or

HIPAA PHI Privacy or Security Incidents.

By email:  admin@angeleshealthcenter.com

By mail:  Angeles Health Center

                Dr. Vanessa Ho, Compliance Officer

                3660 Park Sierra Dr. #110

                Riverside, CA 92505

2. All reports will be investigated and maintained securely at the health center and will be accessed only with 

permission of the Compliance Officer. 

3. Reports are not addressed satisfactorily can be escalated to:

IEHP Compliance Hotline: (866) 355-9038

By email: compliance@iehp.org

The Office of the Inspector General

By phone: (800) HHS-TIPS (447-8477)

By email: Htips@oc.dhhs.gov

DHCS Medi-Cal Fraud Hotline

By phone: (800) 822-6222

By email:  fraud@dhcs.ca.gov

NON-RETALIATION POLICY

Angeles Health Center takes all allegations of noncompliance seriously and will maintain the confidentiality of all reports. All persons may report anonymously without fear of intimidation and/or retaliation. Any non-compliance, HIPAA, or Security

incidents will be reported to the appropriate entities including the Compliance Officer. 

FORMS

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HIPPA Privacy Breach Incident Report Form

Fraud, Waste and Abuse Report Form