What must be established by entities receiving more than $5 million in annual Medicaid payments?

Entities that receive more than $5 million in annual Medicaid payments are required to establish written policies and procedures that include education on the False Claims Act (FCA). This requirement arises from the need to ensure that healthcare providers are aware of their obligations under the FCA, which prohibits fraud against the government, including Medicaid.

Written policies provide a framework for compliance, setting forth the responsibilities of the entity and the obligations of its employees regarding billing and claims submission. Education on the FCA helps ensure that all staff members understand what constitutes fraudulent behavior and the potential consequences of submitting false claims. This proactive approach is intended to foster a culture of compliance and ethical behavior within the organization, significantly reducing the risk of fraudulent activities.

While compliance programs, fraud investigative teams, and billing manuals are important components of a robust compliance strategy, the specific requirement under this context focuses on written policies and education related to the FCA. Establishing these policies is key to preventing fraud and ensuring compliance with federal regulations, thereby protecting both the integrity of the Medicaid program and the entity itself.