Which entities could be violators of fraud in the compliance context?

• A. Physicians
• B. Hospital
• C. Billing service
• D. All of the above

Answer: (D)

Fraud in healthcare compliance can be committed by any party involved in the creation or submission of claims. Physicians may bill for services not performed, misrepresent the level of service, or order unnecessary tests to obtain higher reimbursement. Hospitals can inflate charges, bill for services not provided, engage in unbundling, or submit duplicate claims. Billing services that handle claims for providers can fraudulently process or alter documentation to push through improper payments or fail to detect and correct errors. Because liability can attach to any entity that participates in or benefits from false claims, all of these could be violators. So, all of the above could be violators.