UW Medical Foundation Contractor and Vendor Information

You or your organization may qualify as a “contractor” or “agent” of the University of Wisconsin Medical Foundation, Inc. (“UWMF”), as defined in Section 6032 of the Federal Deficit Reduction Act of 2005 (the “Act”). As you may well know the Act was passed in 2006 and requires that certain health care providers, including UWMF, undertake the following:
[A] Establish written policies for all employees of the entity (including management), and of any contractor or agent of the entity, that provide detailed information about the False Claims Act established under sections 3729 through 3733 of title 31, United States Code, administrative remedies for false claims and statements established under chapter 38 of title 31, United States Code, any State laws pertaining to civil or criminal penalties for false claims and statements, and whistleblower protections under such laws, with respect to the role of such laws in preventing and detecting fraud, waste, and abuse in Federal health care programs (as defined in section 1128B(f)); and

[B] Include as part of such written policies, detailed provisions regarding the entity's policies and procedures for detecting and preventing fraud, waste, and abuse; and

[C] Include in any employee handbook for the entity, a specific discussion of the laws described in subparagraph (A), the rights of employees to be protected as whistleblowers, and the entity's policies and procedures for detecting and preventing fraud, waste, and abuse.''
The Centers for Medicare & Medicaid Services (“CMS”) of the Department of Health & Human Services interpreted the Act as requiring that UWMF establish and disseminate to its employees, contractors and/or agents, written policies as outlined above, detailing UWMF principles, policies and procedures for detecting and preventing waste, fraud, and abuse, as well as corporate protections for whistleblowers. CMS further determined that UWMF must require that all its health care contractors or agents adopt these same policies and procedures.

Accordingly, please review the current UWMF False Claims – Whistleblower Protection Policy. In the future, UWMF will comply with CMS guidance and address its obligations under the Act through the addition of language that requires you to adopt all such policies and procedures in any renewal contract(s) or agreement(s).

Additional information about the Act may be found online at www.cms.hhs.gov. Questions or concerns regarding interpretation of the Act may be submitted via e-mail to CMS at medicaid_integrity_program@cms.hhs.gov.