As of January 1, 2007, certain entities, including hospitals and nursing homes, may be required to provide education to their employees, contractors and agents. According to the new education requirements of the Defi cit Reduction Act of 2005 (the “DRA”), entities that receive or make at least $5 million in Medicaid payments must change their written policies and/or their employee handbooks to include information on federal and state false claims acts, whistleblower protections and the providers’ own policies on detecting and preventing fraud. While there is some question as to whether entities covered by the education requirements must implement these education requirements now or may wait until the states amend their own Medicaid plans, we recommend that covered entities begin to implement the education requirements of the DRA.
Click on the PDF link above to view the full memorandum.