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Kaiser Permanente and other Teaching Hospitals GME Graduate Medical Education Program



Kaiser Permanente to pay

$3.75 for false billing -
GME Residents did the work

False bills to government/
Medicare prompt a settlement by Kaiser - Dec 2009
Kaiser Permanente has agreed to pay $3.75 million
http://fines.kaiserpapers.org/false-billing.html

December 4, 2009
...teaching physicians purportedly
supervised the work of medical
residents or students. The
patients' records failed to show
that the instructors were present,
authorities said. - SF Chronicle - Bob Egelko writer

mirrored at: http://gme.kaiserpapers.org/no-doctor.html


October 27, 2009
Thomas J. Nasca, M.D., MACP
CEO, Accreditation Council for
Graduate Medical Education
open letter

2009-2010
Accreditation Council for
Graduate Medical Education
Data Resource Book

Selected Articles on the
Patient Hand-off Compiled by
Ingrid Philibert, Updated
December2007                                                                                          To describe the characteristics
of and factors contributing to
trainee errors, the authors
analyzed malpractice claims
in which trainees were judged
to have played an important role
in harmful errors.

Protecting Residency Programs’
ACGME Compliance Documents
from Disclosure Under
State Public Records Acts


Financial Gain from the GME Program

Funding for the GME Program -
Where does the money come from?

Patient Safety or non Safety

Some known cases		Using federal grant dollars for unjust enrichment, personal gain, or other than their intended use is a form of theft, subject to criminal and civil prosecution under the laws of the United States.

Federal grant dollars are susceptible to several forms of financial theft, most commonly in the form of specific federal violations, including:
 1. Embezzlement
 2. Theft or Bribery concerning programs receiving Federal funds
 3. False Statements
 4. False Claims
 5. Mail Fraud and Wire Fraud

Each of these violations of law are subject to criminal prosecution, fines, restitution, and civil
penalties.

When business entities, individuals, communities, and other organizations receive federal grant dollars, they are entrusted with their appropriate expenditure.

Grant fraud is most often committed by:
 1. Grant recipients, company officers, business partners, board
    members, and managers.
 2. Bookkeepers, financial staff, and employees.
 3. Contractors and subcontractors engaged with the recipient.
 4. Recipient consultants.

        Common Grant Fraud Scenarios
Grant fraud occurs in many ways, but some of the most common fraud scenarios include:

1. Charging personal expenses as business expenses against the grant.
2. Charging for costs which have not been incurred or are not attributable to the grant.
3. Charging for inflated labor costs or hours, or categories of labor which have not been incurred (for example, fictitious employees, contractors, or consultants).

Review the entire document at:
http://gme.kaiserpapers.org/pdfs/GrantFraud.pdf

"There is an evolving, very strong concern progressing to alarm among some, that our undergirding principle of
graded authority and progressive responsibility coupled with graded and diminishing (but appropriate) supervision
is eroding in the contemporary American teaching hospital. While appearing to occur contemporaneously with
resident duty hour limits, this erosion appears to have had its roots in the latter portion of the previous decade. An
unintended consequence of the I.L. 372 interpretations leading to the PATH Audits of the late 1990’s was the
beginning of a significant erosion of the delegation of authority for patient care of residents and fellows. The
medical liability insurance crisis of earlier this decade, and the associated “risk management” policies and
procedures put in place in most institutions have had a chilling effect on the delegation of authority and
responsibility, especially to senior residents, for complex decision making and performance of procedures. The
pressures placed on productivity and revenue generation by academic clinical faculty, coupled with the compliance
motivated performance and documentation of key aspects of patient care in order to bill for services has removed
the resident from the central role in provision of patient care in many teaching settings. Finally, the enactment of
resident duty hour standards, as appropriate and well meaning as intended, have had in some settings the
unintended consequence of removal of the resident from the previously held “pivotal role” in the care of patients
on the teaching service. It is the “concern evolving to alarm” that we may have crossed a critical point, resulting in
inadequate meaningful patient responsibility in a critical mass of the residents’ experience. This, it is feared, will
lead to inadequately trained clinicians entering the unsupervised practice of medicine. "

Written:
October 27, 2009
Thomas J. Nasca, M.D., MACP
CEO, Accreditation Council for Graduate Medical Education
Vice Chair, Task Force for the Revision of ACGME Resident Duty Hour Standards 
entire letter available at:

mirrored for historical purposes at: http://gme.kaiserpapers.org/pdfs/NascaLetterCommunity10_27_09-1.pdf











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