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DETROIT WAYNE MENTAL HEALTH AUTHORITY

Compliance

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Compliance Office

The role of the Detroit Wayne Mental Health Authority’s (Authority) Compliance Office is to establish internal safeguards to effectively provide quality behavioral health and substance abuse services to Consumers in Wayne County within the parameters of federal and state regulation. The Authority’s Compliance motto is “Do the Right Thing,” which requires the Authority and its Providers to provide services in a manner that promotes honesty, integrity and ethics. 

7 Elements of a Successful Compliance Program
 
The federal Office of Inspector General (OIG) has established seven (7) elements for an effective compliance program to monitor, detect, correct and report fraud, waste and abuse:
  1. The Development of Policies and Procedures (i.e. standard of conduct, compliance plan etc.).
  2. Oversight by appointing a compliance officer and compliance committee;
  3. Compliance Education and Training;
  4. Monitoring and Auditing;
  5. Reporting and Investigation (of suspected fraud, waste and abuse);
  6. Enforcement and Discipline; and
  7. Response and Prevention.
The aforementioned elements have been incorporated into the Authority’s Compliance Plan and Standard of Conduct Policy.
Required Training

The Authority requires each employee and Provider Network to take the following training through its Virtual Center of Excellence (VCE) Portal (www.vceonline.org) on an annual basis:

  1. Fraud, Waste and Abuse
  2. Compliance Training
  3. HIPPA (type of training depends on role and title).
Reporting Fraud, Waste and Abuse

You may report any issue and ask questions of the Authority’s Compliance Officer, Eric W. Doeh, by email, postal mail, or telephone:

Detroit Wayne Mental Health Authority
Compliance Office
707 W. Milwaukee, 5th Floor
Detroit, MI 48202
313-344-9099
 
Or
 
You may report complaints anonymously to 313-833-3502. If you identify yourself, the Authority will maintain anonymity to the extent provided by law.

or you may report to state OIG:

Michigan Department of Health and Human Services
Office of Inspector General
PO Box 30062
Lansing, MI 48909
Ph: 855-MI-Fraud (643-7283).

 
Examples of Fraud, Waste and Abuse
 
The following is a partial list of examples of fraud, waste and abuse: 
  • Billing for medical services not actually performed 
  • Providing unnecessary services 
  • Billing for more expensive services 
  • Billing for services separately that should legitimately be one billing 
  • Billing more than once for the same medical service 
  • Billing for unnecessary tests or missed appointments
  • Dispensing generic drugs but billing for brand-name drugs 
  • Giving or accepting something of value (cash, gifts, services) in return for medical services, (i.e. kickbacks) 
  • Falsifying cost reports
  • When someone lies about their eligibility or medical condition
  • Individuals forging prescriptions
  • Individuals selling their prescriptions to other
Policies

The Authority has established the following compliance policies and procedures to prevent fraud, waste and abuse and are available for download:

  1. Compliance Plan
  2. Compliance Reporting Policy
  3. Conflict of Interest Policy
  4. Investigation Policy
  5. Standards of Conduct
  6. Fraud Waste and Abuse Policy