Phone: (651) 665-9795

Fax: (651) 665-9796

Monday - Friday: 8:30 am - 5:00 pm

Accurate Billing Practice and Fraud Prevention Policy

Policy Statement and Purpose

The Centers for Medicare and Medicaid Services (CMS) require agencies to provide written policy guidelines delineating appropriate rules of conduct regarding the detection, correction, and prevention of fraud, waste, and abuse.  This form is designed to raise clients’/employees’ awareness about their role in facilitating accurate billing and to communicate the policy of Divine Healthcare Network regarding fraud, waste, and abuse.


The practice of accurate billing in home health care begins with correct documentation of services rendered and time served in charting forms (timecards). To assure accurate billing, Divine requires clients to verify that the times and services documented by employees in their charting forms reflect actual times worked and services authorized in the client’s care plan. By signing an employee’s charting form, clients acknowledge that they have reviewed it for completeness and accuracy. 


It is also Divine’s policy, following a thorough investigation and finding of wrong-doing, that any intentional act to defraud Medicare, Medicaid, private insurance, or any government-funded programs and services shall constitute grounds for discharging a client and/or employee from the agency. Fraudulent acts, among other examples, include employees misrepresenting hours worked on timecards, allowing employees to claim un-worked hours while the client has traveled or is hospitalized, or colluding with employees to share earned wages.


Fraud, Waste, and Abuse Defined

The Centers for Medicare and Medicaid Services define fraud, waste, and abuse as follows:

  • Fraud: An intentional act of deception, misrepresentation or concealment in order to gain something of value. E.g., billing for services that were never rendered.
  • Waste: Over-utilization of services (not caused by criminally negligent actions) and the misuse of resources.
  • Abuse: Excessive or improper use of services or actions that are inconsistent with acceptable business or medical practice. Refers to incidents that, although not fraudulent, may directly or indirectly cause financial loss. E.g., charging in excess for services or supplies.


Compliance Plan and Reporting Fraud, Waste, and Abuse

In accordance with CMS requirements, Divine runs monthly fraud prevention training classes for all its employees and has established a Compliance Team comprising of the administrator, director of nursing, office manager, and director of healthcare education and community outreach to respond proactively to any concerns clients and employees may have.  Clients and employees may report any violations directly to any members of the compliance team by calling (651) 665-9795. All reported violations are subject to investigation, and retaliation is prohibited.