The Fraud, Waste, and Abuse (FWA) Prevention Program aligns with Fred Hutch’s Standards of Conduct, which reflect our shared responsibility to act ethically, follow laws and policies, and protect the integrity of our patient care, research, and operations.
Fred Hutch is committed to the responsible use of its own resources, as well as those entrusted by third-party payors, sponsors, and government agencies. The FWA Prevention Program supports this commitment by establishing and adopting institutional policies and training outlining how potential concerns are prevented, identified, reported, and addressed.
Fraud occurs when people or organizations intentionally misrepresent information to secure some benefit for themselves or others. Wasteful and abusive practices, directly or indirectly, result in unnecessary costs, such as performing services that are not medically necessary or submitting claims for services without legal entitlement to that payment.
Examples of FWA
- Submitting false claims to Medicare or other payors
- Falsifying research data or grant applications
- Accepting kickbacks of inappropriate gifts
- Failing to disclose foreign affiliations on grant proposals
- Billing for services not rendered or unnecessary services
Reporting FWA
To confidentially and/or anonymously report any known or suspected fraud, waste, and abuse activities, contact:
Concerns involving federal healthcare programs may also be reported to the U.S. Department of Health and Human Services Office of Inspector General (OIG) at 1-800-HHS-TIPS (1-800-447-8477) or online at oig.hhs.gov
Individuals who report concerns in good faith are protected from retaliation.
Legal and Regulatory
The FWA Prevention Program is guided by federal and state laws that prohibit fraudulent billing, improper financial relationships, and misuse of public funds. These include the False Claims Act, Anti-Kickback Statute, Stark Law, and the Washington Medicaid False Claims Act. The Fred Hutch FWA Prevention Program aligns with compliance expectations from the Centers for Medicare & Medicaid Services (CMS) and the Washington State Health Care Authority.
Regulations include but are not limited to:
- False Claims Act (FCA), 31 U.S.C. §§ 3729-3733
- Anti-Kickback Statute (AKS), 42 U.S.C. Section 1320a-7b(b)
- Physician Self-Referral Law (Stark Law), 42 U.S.C. Section 1395nn
- Criminal Health Care Fraud Statute, 18 U.S.C. Section 1347
- Washington State Medicaid Fraud False Claims Act (RCW 74.66)
- Civil Monetary Penalties Law (CMPL), 42 U.S.C. Section 1320a-7a
- Exclusion Statute, 42 U.S.C. Section 1320a-7