The settlement agreement is Healogics` final chapter in the defense against three FCA-Qui Tam claims filed in 2014 and 2015. The grievances that were resolved by the settlement agreement stemmed from two of Qui Tam`s three complaints. While each of Qui Tam`s complaints contained allegations of medically unnecessary HBO therapy billed to Medicare, its procedures and circumstances were very different and remarkable: the claims governed by this agreement are only allegations, and there was no finding of liability. We are committed to addressing all identified compliance concerns and putting in place mechanisms to bring compliance concerns to our home. All employees are expected to report suspected violations of federal health program requirements, violations of Healogics guidelines and procedures, and violations of this code. You can report these concerns by calling our anonymous compliance number at 888-999-9460, emailing us at firstname.lastname@example.org, or completing the Personnel Compliance Form available under hotline.healogics.com. The Companies Directive prohibits retaliation against those who report a compliance issue. Infringements of this directive must be reported. We strive to do the right thing every day, with everything we do and for every patient we serve.
Healogics` compliance department wants to be a trusted partner in promoting integrity, transparency, accountability and a culture of ethical behavior that protects the reputation, mission, vision and values of Healogics, its employees, companies and related partners. In particular, the transaction agreement does not provide for payments to Van Raalte relators, under which the Wilcox relator will receive 19% of the total payments in the transaction. Medicare covers HBO treatment, a modality in which the entire body is exposed to oxygen under increased atmospheric pressure, as an additional treatment to treat certain chronic wounds. The deal announced today resolves allegations that Healogics knowingly filed or provoked false claims with Medicare from 2010 to 2015 for medically unnecessary or inappropriate HBO therapy. In September 2015, the government filed a communication on its choice to refuse intervention “at that time” in the action. In October 2015, the reporters voluntarily rejected their appeal and the government agreed to the dismissal.