1. Knowingly presents, or causes to be presented, a false or fraudulent claim for payment or approval to any federal healthcare program
2. Knowingly makes, uses or causes to be made or used a false record or statement to get a false or fraudulent claim paid; or
3. Conspires to defraud the government by getting a false of fraudulent claim allowed or paid.

1. Billing for procedures not performed
2. Violation of another law, for example a claim was submitted appropriately but the service was the result of an illegal relationship between a physician and the Hospital (physician received kick-backs for referrals)
3. Falsifying information in the medical record
4. Billing of medically unnecessary services
5. Billing for non-covered services
6. Billing for incorrect level of service

A person may not:

1. Knowingly present or cause to be presented a false or fraudulent claim for payment or approval
2. Knowingly make, use, or cause to be made or used a false record or statement material to a false or fraudulent claim
3. Conspire to commit a violation under this subtitle
4. Have possession, custody, or control of money or other property or on behalf of the State under a State health plan or State health program and knowingly deliver or cause to be delivered to the State less than all of that money or other property
5. Be authorized to make or deliver a receipt or other document certifying receipt of money or other property used or to be used by the State under a State health plan or program and intending to defraud the State or the Maryland Department of Health make or deliver a receipt or document knowing that the information contained in the receipt or document is not true
6. Knowingly buy or receive as a pledge of an obligation or debt publicly owned property from an officer, employee, or agent of a State health plan or a State health program who lawfully may not sell or pledge the property
7. Knowingly make, use, or cause to be made or used, a false record or statement material to an obligation to pay or transmit money or other property to the State
8. Knowingly conceal or knowingly and improperly avoid or decrease an obligation to pay or transmit money or other property to the State; or
9. Knowingly make any other false or fraudulent claims against a State health plan or program
10. A person who is found to have violated the aforementioned subsection is subject to Civil Monetary Penalty.

In Maryland, the Maryland False Health Claims Act (MFHCA) prohibits a person from, among other things, knowingly presenting or causing to be presented a false or fraudulent healthcare claim for payment. The MFHCA specifically provides that a mistake or a negligent action that causes a false or fraudulent claim to be presented for payment is not a violation of the MFHCA. The Federal False Claims Act, under the MDFCA, qui tam actions must be supported by the intervention of the Office of the Maryland Attorney General in order to proceed.

You are not required to report a possible false claims act violation to Johns Hopkins Health Plans or JHHSC first. You may report directly to the federal Department of Justice, Civil Division Fraud Section or to the state Attorney General.

Johns Hopkins Health Plans or JHHSC will not retaliate against you for reporting anyone of a possible false claims act violation.

Both the Federal and State False Claims Acts have Whistleblower Protections which prohibits retaliation against the reporter.

Whistleblower refers to an individual who reports any kind of information or activity that alleges any violation of regulation, statute, contract, policy or unethical behavior that may be indicative of an individual or entity committing fraud, waste or abuse against a government program.

If you see something that is not right, or witness something that resembles one of the examples of a false claim discussed above, you are encouraged to:

• Report it to the Johns Hopkins Health Plans Compliance Office at 410-424-4996 / 1-844-422-6957 for further investigation.
• If you are not comfortable doing this or do not see action in response to your report; call the JHHSC Corporate Compliance Hotline at 1-844-SPEAK2US (1-844-773-2528) or via email at JohnsHopkinsSPEAK2US.com 24 hours, 7 days a week.

All Johns Hopkins Health Plans providers, contractors, subcontractors, employees and vendors are required to report concerns about actual, potential, or perceived misconduct to the Johns Hopkins Health Plans Compliance Department. You may reach the Department using one of the methods listed immediately below.

• Mail: Johns Hopkins Health Plans
  Corporate Compliance Department
  7231 Parkway Drive, Suite 100
  Hanover, MD 21076
• Call: 410-424-4996 or toll free at 1-844-422-6957
• Fax: 410-762-1527, and
• Email: [email protected]

Beginning October 1, 2015, all Johns Hopkins Advantage MD providers, contractors, subcontractors, employees and vendors are required to report concerns about actual, potential, or perceived misconduct to the Johns Hopkins Advantage MD Compliance Department. You may reach the Department using one of the methods listed immediately below.

• Mail: Johns Hopkins Health Plans Medicare Compliance Department
  7231 Parkway Drive, Suite 100
  Hanover, MD 21076
• Call: 410-762-1575 or toll free at 1-844-697-4071 (TTY: 711)
• Fax: 410-762-1502, and
• Email: [email protected]
• Hours of Operation: Monday through Friday 8 a.m.- 5 p.m. (Voicemail available after hours)

Johns Hopkins Health Plans encourages timely disclosure of such concerns and expressly prohibits any adverse actions directed against any person for making a good faith report of such concerns. No one at Johns Hopkins Health Plans may retaliate against you if you inform them or a government agency of a possible False Claims Act violation. All Johns Hopkins Health Plans employees, providers, contractors, subcontractors, and vendors have a right to oppose or refuse to engage in acts that they believe, in good faith, are unethical, improper, or unlawful, provided that the manner of opposition is reasonable and the questionable act is immediately reported to the Johns Hopkins Health Plans Compliance Department using one of the contact methods listed above.