Compliance & Fraud-Waste-Abuse

Everyone is required to report suspected instances of Fraud, Waste, and Abuse (FWA).  The Coherent General Standards of Conduct states this obligation.  Coherent will not retaliate against any person for making a good faith effort in reporting.

To detect fraud, waste, and abuse you need to know the Law.

Criminal Fraud: Knowingly and willfully executing, or attempting to execute, a scheme or artifice to defraud any health care benefit program; or to obtain, by means of false or fraudulent pretenses, representations, or promises, any of the money or property owned by, or under the custody or control of, any health care benefit program.

18 United States Code §1347

In other words, “Intentionally submitting false information to the government or a government contractor in order to get money or a benefit.”

Waste: overutilization of services, or other practices that, directly or indirectly, result in unnecessary costs to the Medicare Program. Waste is generally not considered to be caused by criminally negligent actions but rather the misuse of resources.

Abuse: includes actions that may, directly or indirectly, result in unnecessary costs to the Medicare Program. Abuse involves payment for items or services when there is not legal entitlement to that payment and the provider has not knowingly and or/intentionally misrepresented facts to obtain payment.

There are differences between fraud, waste, and abuse.

One of the primary differences is intent and knowledge.

  • Fraud requires the person to have an intent to obtain payment and the knowledge that their actions are wrong.
  • Waste and abuse may involve obtaining an improper payment but does not require the same intent and knowledge.

Do not be concerned about which category the suspected violation is called.

Just report any concerns to the Coherent compliance department. The Compliance representatives will investigate and make the proper determination.

To report suspected FWA or any suspected non-compliant activities please use one of methods offered below: