LOS ANGELES COUNTY
DEPARTMENT OF MENTAL HEALTH
  Policy 106.05 Fraud, Waste, and Abuse Prevention
 
  PROCEDURES
  1. Standards of Business And Professional Ethics
     
    1. As applicable, Los Angeles County Department of Mental Health (DMH/Department), Mental Health Contractors, and other workforce members who are licensed, certified or accredited, should be aware of, and periodically review the code of ethics associated with their profession. This periodic review will reinforce expectations regarding business and professional conduct.
       
  2. Compliance with Federal, State, And County, Statutes, Laws, Regulations, Policies And Procedures
     
    1. DMH and Mental Health Contractor managers and supervisors shall monitor the employees, and review their work product to ensure compliance with applicable Federal, State, and County, statutes, laws, regulations, policies and procedures. This includes, but is not limited to the Federal False Claims Act and the State False Claims Act.
       
    2. Compliance Program Office (CPO) will monitor compliance with Federal, State, and County, statutes, laws, regulations, policies and procedures. Monitoring will be planned and will be based on periodic risk assessments.
       
    3. Audits may be conducted by Federal, State, or County Auditor-Controller personnel, or by DMH organizational units other than CPO, for purposes of determining compliance with Federal, State, and County statutes, rules, regulations, policies and procedures. 
       
    4. DMH and Mental Health Contractors shall implement audit recommendations as appropriate to ensure compliance with Federal, State, and County statutes, rules, regulations, policies and procedures.
       
  3. Reporting Any Actual or Perceived Compliance Violations
     
    1. DMH employees are expected to exhaust all internal means - call an immediate supervisor, the Compliance Program Office, or the Auditor-Controller Fraud Hotline - for correcting perceived or actual compliance violations prior to notifying law enforcement or non-County officials to initiate an investigation or other corrective action.
       
    2. DMH Policy 106.01 advises DMH employees, other workforce members, and stakeholders [includes contractors] that there are at least three ways to report actual or perceived compliance violations:
       
      1. Employees and other workforce members may discuss the issues with their supervisor or manager, or
         
      2. Call the Compliance Program Office at (213) 739-2390; or
         
      3. Auditor-Controller Los Angeles County Fraud Hotline website or phone, (800) 544-6861.
         
    3. Contract employees should work with their organization first and may also notify the DMH CPO at (213) 739-2390 or the County fraud hotline at (800) 544-6861 if their agency does not respond or implement corrective actions. 
       
    4. The DMH CPO will, in coordination with the Auditor-Controller, conduct timely reviews and/or audits of alleged compliance violations that may have occurred within DMH and Mental Health Contractor operations to detect erroneous practices and cause them to be stopped and corrected in a timely manner.
       
  4. Training 
     
    1. The CPO will provide annual training to DMH employees and other work force members. This training will include: integrity and ethics and other areas of concern.
       
    2. Contractors are to ensure their employees and other workforce members are adequately trained.
       
  5. Policies and Procedures
     
    1. DMH will maintain a set of policies and procedures. (DMH Policy 106.17)
       
    2. Contractors should have policies and procedures available as reference guides for their employees.
       
  6. DMH Distribution/Accessibility Procedures
     
    1. DMH will distribute this policy to DMH employees, contractors and agents, so that they are aware of, and will abide by, DMH policies and practices to avoid fraud, waste and abuse.
       
      1. CPO will coordinate with DMH Human Resources and will distribute to all its employees a copy of this policy.
         
      2. CPO will coordinate with DMH Contract Development and Administration Division and to distribute a copy of this policy to all of DMH’s contractors and agents.
         
    2. To ensure this policy is readily accessible to DMH employees, contractors and agents:
       
      1. DMH will maintain a copy of this policy on the Policy and Procedure websites accessible to employees, contractors, and agents. 
         
      2. DMH will distribute a copy of this policy to all DMH policy manual holders; with instructions to insert the policy in the manual.
         
      3. DMH will add this policy to the DMH Employee Reference Manual. This will ensure distribution to the new employees.
         
  7. DMH Contractors and Agents' Responsibilities
     
    1. DMH contractors and agents will distribute a copy of this policy to all of their existing and future employees and other work force members.