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Whistle Blower Protection Policy

 Revised 7/17/07

Orange Grove Center

False Claims Act and Whistleblower Protection Policy

 

Policy

The policy of Orange Grove Center is to require all staff members to report all known or suspected violations of the Federal False Claims Act (“FFCA”) or the Tennessee False Claims Act (“TFCA”) (collectively referred to as “FCA”), as described below.  A person violates the FCA by knowingly submitting, or causing another to submit, false claims for payment of government funds.  Examples of violations of a FCA are (i) submission of a claim to Medicare for payment for services not rendered, or (ii) falsification of a time and effort report in connection with a claim for reimbursement from government grant.  It is also the policy of Orange Grove Center that persons reporting such suspected violations (sometimes referred to as “whistleblowers”) will not be retaliated against (as defined in Section III. below) for making such reports in good faith.

Procedure

            I.          Definition

                        A.        FFCA (located at 37 U.S.C.  3729) states, in part, that it is a violation of Federal law for any person to knowingly present, or cause to be presented, to the Federal Government a false or fraudulent claim for payment or approval or who knowingly makes or causes to be made a false record in order to get a false claim paid by the Federal Government.  A violation of the FFCA can result in a civil penalty of not less than $5, 500 and not more than $11, 000, plus 3 times the amount of damages sustained by the Federal Government.

                        B.        TFCA (located at T.C.A.  4-18-103) states, in part that it is a violation of State law for any person to knowingly present to the State of Tennessee or political subdivision a false claim for payment or approval or who knowingly makes or causes to be made a false record in order to get a false claim paid by the State of Tennessee.  A violation of the TFCA can result in a civil penalty of not less than $2,500 and not more than $10,000 for each false claim, plus 3 times the amount of damages sustained by the State or political subdivision.  Unlike the FFCA, it is a violation of the TFCA for a person to make an inadvertent submission of a false submission after discovering the error.

            II.        Reporting a Known or Suspected Violation of FFCA or TFCA

                        A.        A staff member is expected to report any known or suspected violation of either the FFCA or the TFCA to the staff member’s supervisor, department head or chair or Orange Grove Center Compliance Officer (Jenny Foster - (423) 629-1451).

                        B.        A staff member may also report known or suspected violations of the FFCA to the following Federal hotline, 1-800-8484 or by email at HHSTips@OIG.HHS.gov.

                        C.        All persons making reports of compliance concerns are assured that such reports will be considered confidential to the extent permitted by law.  Such reports will be shared with others only on a bona fide need-to-know basis.

            III.       Whistleblower Protection

Orange Grove Center prohibits retaliation and will take no adverse action  against persons for making such reports in good faith (“whistleblowers”), even if the report turns out not to be correct.  Retaliation and adverse action include the following: discharge, demotion, suspension, harassment, denial of promotion, transfer or in any other manner discriminating or threatening to discriminate against a staff member in the terms and conditions of the staff member’s employment.  Any staff member who believes that he or she has been subjected to or affected by a retaliatory conduct for reporting a suspected violation of a FCA or for refusing to engage in activity that would be a violation of a FCA should report such retaliation to the Orange Grove Center Compliance Officer (Jenny Foster - (423) 629-1451). The Compliance Officer will be responsible for investigating such report or referring the report to the appropriate person for timely investigation.

This page was last updated on Mon Oct 7, 2013.

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Orange Grove Center • 615 Derby Street • Chattanooga, Tennessee 37404 • Phone: 423.629.1451