Reporting Compliance Concerns
If you ever have a question about a particular legal or ethical requirement or if you become aware of another employee's breach of his or her legal or ethical responsibility, you should first consult your immediate supervisor. In some cases, however, you may feel uncomfortable about this approach. You may feel intimidated or fear that someone may retaliate against you for reporting a problem. You may believe that your supervisor will not follow-up and take necessary action to correct the problem or the problem may involve your supervisor. You may even feel that it is simply not worth getting involved. The danger is, if you allow these feelings to prevent reporting, the problem may go unnoticed.
Types of violations that should be reported:
- Billing for services not rendered or items not provided
- Falsifying claim forms to receive overpayment for services provided
- Falsifying certificates of medical necessity and billing documents for services not medically necessary
- Duplicate billing
- Any inaccurate billing that could result in the University receiving reimbursement
- Any event that would require the University to disclose wrongful activity to a governmental agency, including unallowable costs in any claims for reimbursement.
Employees can report allegations of wrongdoing through established administrative processes and procedures of the Health Science Center, including but not limited to those established:
For fraud, embezzlements, misappropriations and other fiscal irregularities, see Section 2.6.3 of the Handbook of Operating Procedures (HOP), "Fraud, Abuse and False Claims Act".
Angela D’Anna, CIA, CISA, CDF, CHC
Chief Audit Executive for Internal Audit & Consulting Services
Phone: (210) 567-2380, Fax: (210) 567-2373
For discrimination, sexual harassment and sexual misconduct, see Sections 4.2.1 and 4.2.2 of the HOP, "Nondiscrimination Policy and Complaint Procedure" and "Title IX Sexual Harassment/Sexual Misconduct Policy".
Title IX Director
Phone: (210) 567-2982
For complaints concerning wages, hours of work, working conditions, performance evaluations, merit raises, job assignments, reprimands and human resource issues, see Section 4.9.5 of the HOP, "Grievance Policy and Procedures".
Michael Tesh, MBA
Vice President for Human Resources
Phone: (210) 567-2597, Fax: (210) 567-6790
To report compliance issues, wrongdoing, improper or illegal conduct, see Section 2.5.1 of the HOP, "Office of Regulatory Affairs & Compliance".
Gail Madison-Brown, RN, JD, CHC
Chief Compliance Officer for Regulatory Affairs & Compliance
Institutional Compliance Officer/Privacy Officer
Phone: (210) 567-2014, Fax: (210) 567-9285
- For billing practices that cause you to suspect potential fraud and abuse.
Department of Health & Human Services
Office of Inspector General hotline
- You may also report suspected fraud, waste and abuse to the:
State Auditor's Office Hotline
Phone: 1-800-TX-AUDIT (1-800-892-8348)
The State Auditor's Office provides additional information at it's web site, http://sao.fraud.state.tx.us.
The University has established a dedicated ComplianceLine, a "1-800" external reporting mechanism for identifying improper or illegal conduct of University employees, students, vendors, or independent contractors. You may also contact the Office of Regulatory Affairs & Compliance in person, by telephone, or by written communications.
All reports to the Office of Regulatory Affairs & Compliance will be reviewed. If wrongdoing is discovered, the University will take appropriate action. You have the University's pledge that no retaliation will be taken against anyone making a report in good faith. In addition, every effort will be made to protect your privacy whenever possible.
Reporting compliance wrongdoing is a serious issue, and it should not be used frivolously or to harass another employee.
If the alleged wrongdoing is significant or widespread or applies to The University of Texas System as a whole, or if you are uncomfortable reporting the matter to any of the above offices, you may submit a report to one of the following:
- UT System-wide Compliance Hotline: (888) 228-7786
- UT System-wide Compliance Contact Us
- UT System-wide Compliance Officer
Phillip B. Dendy
Phone: (512) 499-4389, Fax: (512) 579-5085