Information about False Claim Recovery for Employees, Contractors and Agents

Pursuant to Section 6032 of the Deficit Reduction Act of 2005 (the "DRA"), Vanguard has established a written Policy for all of its system-wide employees and for all of its system-wide contractors or agents that provides detailed information about false claims, false statements and whistleblower protections under applicable federal and state fraud and abuse laws.

In December 2006, CMS published guidance about implementation of Section 6032 indicating, among other things, that certain Vanguard contractors or agents (the "Covered Contractors/Agents") should themselves each adopt a policy in compliance with Section 6032. According to CMS, Covered Contractors/Agents means any contractor, subcontractor, agent or other person which or who, on behalf of any Vanguard entity, furnishes or otherwise authorizes the furnishing of Medicaid health care items or services, performs billing or coding functions, or is involved in monitoring of health care provided by any Vanguard entity. Thus, pursuant to this CMS guidance, Vanguard not only requests that its Covered Contractors/Agents disseminate this Vanguard Policy to their employees, but also adopt this Policy as their own policy.

Click here to view information about False Claims Recovery for employees, contractors and agents.