Approval/Effective Date: 8/9/2011
Last Reviewed: 1/17/2023
Policy: Violations of the Compliance Program or any applicable Federal or State laws or regulations uncovered as a result of an investigation or any other means will be addressed as appropriate to the situation. University of Washington School of Dentistry will take reasonable steps to prevent inappropriate activity from recurring.
Purpose: The purpose of this policy is to set forth the procedures that will be used by the University of Washington School of Dentistry to respond to violations of the Compliance Program or any applicable Federal and State laws or regulations.
If, through an investigation or by any other means, the School of Dentistry uncovers inappropriate activity on the part of any faculty member, staff, student or business unit, it will undertake the following steps as it deems warranted by the severity and extent of the suspected violation.
Evaluation of Extent and Severity: In determining the appropriate action steps, the School of Dentistry will base its decision in part on an evaluation of the size and scope of the potential violation. In addition, the School will take into account if billing or other problems appear to be the result of conduct which is intentional, willful, or carried out with reckless disregard for the law.
Discipline: University of Washington School of Dentistry will initiate appropriate disciplinary action against any faculty, student or staff member who has failed to comply with the School of Dentistry’s Compliance Program policies, procedures, and standards of conduct. Sanctions will be applied in accordance with relevant staff personnel policies, faculty bylaws and/or faculty code, and student policies and/or student code as appropriate to the situation. Sanctions will be consistently and fairly applied. Such discipline may result in termination in certain situations. This applies to all faculty, students and staff of the School of Dentistry, regardless of position.
Claims Submission: The School of Dentistry will correct any defective claim submission processes as quickly as possible. In the event continued billing could result in improper payments, the School of Dentistry will immediately stop all billing related to the problem until such time as the offending practices are corrected.
Improper Payments: If the billing or other problem results in improper payments, the School of Dentistry will calculate and repay to the appropriate governmental entity duplicate payments or improper payments resulting from the act or omission.
Notification: The School of Dentistry will notify the following agencies, depending on the extent and severity of the suspected violation:
When only Medicaid is involved, Washington Health Care Authority will be notified. In the event that both Medicare and Medicaid claims are involved, the University of Washington School of Dentistry will notify the programs through the local United States Attorney’s Office or the local office of the United States Department of Health and Human Services Office of the Inspector General Division, as counsel for the University of Washington School of Dentistry deems appropriate.
Education and Training: As appropriate, the School of Dentistry will promptly undertake an education program to prevent future related problems.