Fraud, Waste and Abuse

GSIL has adopted policies and procedures to prevent, detect, deter, and correct fraud, waste, and abuse in accordance with federal and state laws, such as the Federal False Claims Act and the NH False Claims Act, prohibit false claims and other fraudulent activity. Violations of these laws can result in civil actions and penalties. Other laws and regulations governing the integrity of the Medicaid/Medicare Programs are in place to reduce fraud, waste, and abuse. Civil actions and penalties can be brought against the individual committing the crime and the organization. Actions may include loss of all federal/state assistance to the individual committing the crime or allowing the crime to take place.

If you know or suspect activity of this nature, it must be reported immediately. If you are uncertain whether an activity is fraudulent, reach out to Compliance. We do not discriminate or retaliate against any whistleblower, who files in good faith, a report for false claims or participates in a GSIL investigation.

→ GSIL takes all reports of fraud seriously, completes an internal investigation and cooperates with the office of the New Hampshire Attorney General←

Examples of false claims include:

• Billing of items or services that were never rendered
• Billing for hours that are not authorized
• Billing for tasks that are not authorized in the care plan
• Billing for hours while consumer is in the hospital or rehab

Reporting Compliance Concerns
Granite State Independent provides a risk-free method to report compliance concerns.

Your concerns can be reported by:

• Calling 603-410-6577
• Click the Make a Report button at the top of this page

The Compliance voice mail is available 24 hours a day, seven days a week. Calls and web reports are not recorded, and confidentiality is protected up to the limits of the law and to the greatest extent possible. You are encouraged to submit reports relating to violation, misconduct, or areas of concern, as well as asking for guidance related to policies and procedures and providing positive suggestions and stories. Some concerns may be referred to Human Resources.

You should report concerns and suspected misconduct that could violate state or federal laws or GSIL’s policies. Maintaining the high ethical standards of GSIL is everyone’s responsibility. If we become aware of or suspect a situation that might jeopardize the ethical integrity of our organization, it is our obligation to report the circumstances.\

This means we:

• Report any suspicious activity in good faith
• Provide true and complete information
• Keep matters under investigation confidential, unless otherwise required or permitted by law

These duties apply to all of us, including employees, board members, consumers, providers, students, vendor representatives, and independent contractors while carrying out their duties at or on behalf of GSIL.

Boundaries
Every consumer has different boundaries. What one person is comfortable with or thinks is appropriate may not be what someone else considers appropriate. It is important to talk about boundaries with any new ACE.

• Boundaries define the limits and responsibilities of the people with whom you interact with in the workplace. Different types of
  boundaries:
  • Emotional Boundaries (ex. I don’t want to discuss something
    that makes me uncomfortable)
  • Time Boundaries (ex. I need this task completed by a certain time or length of time)
  • Topic Boundaries (ex. I am not comfortable talking about a specific topic)
  • Physical/Space Boundaries (ex. respecting your personal space or areas of the home)
• Remember, both parties hold the right and responsibility of maintaining boundaries and respect goes both ways.
• Keep personal life personal do not bring it into the workplace.
  • Once boundaries are crossed it’s very difficult to go back. It’s important to set boundary or expectations at the beginning of any working relationship.
• You may want to establish some house rules. Here are examples of issues you may want to address when you meet with new ACEs:
• Personal property: ACEs should respect your personal property and ask permission if they want to use it. For instance, you may or may not want to share food and beverages with your ACEs.
• Live-in ACEs: There will be additional issues to discuss with ACEs who live with you. Issues can include free time, common spaces used by everyone, cleaning schedules, use of personal items, payment of bills. You may consider writing down your expectations so they are clear and you and your ACEs can refer back to them.