Anti-Bribery in Real Life
2023 MFCU Report
In 2023 NEMT had 12 convictions of fraud with $159k total recovery.
Two settlements and judgements with a 1 million+ recovery.
Six criminal and one civil patient abuse and neglect cases.
20 arrested, accused in $5 million Medicaid transportation scheme involving Jacksonville company
20 arrested, accused in $5 million Medicaid transportation scheme involving Jacksonville company
Now let’s explore some real-life examples of bribery and how to respond.
Sam is a transportation provider who wants to increase the number of trips he is assigned by the company.
He offers to give Quinn, a company teammate, under the table payments if she assigns more trips to his company.
He tries to convince her that it’s his livelihood and that they can work together to benefit both of them.
Scenario One
How should Quinn respond to the Transportation Provider’s request?
Discussion
If a Transportation Provider does pressure a router, they should report it to the compliance department or the hotline.
Do not ignore it. Report it.
Scott, a company teammate, and a Transportation Provider exchange money in a bar.
Scott’s teammate, Clara, sees the interaction. She knows that recently some Transportation Providers have been offering bribes in exchange for trips.
She reports it to her manager as a potential violation of the company’s Code of Conduct, but the manager takes no action.
Scenario Two
What should Clara do?
Discussion
Clara did the right thing by reporting it to her manager!
But, since her manager didn't take action, Clara has an obligation to escalate her concern.
Do not ignore it. Report it.
What is the company’s position when it comes to accepting bribes?
Unethical.
Unfair.
Illegal.
Confidential.
Anonymous.
No Retaliation.
Ethics Hotline Phone
Ethics Hotline Web
Compliance Officer
Reporting Options
Teammates! Thank you for your participation!