Deficit Reduction Act compliance

Compliance with laws and regulations

Children's Hospital of Wisconsin is required by the Deficit Reduction Act of 2005 to provide to certain contractors information on state and federal False Claims Act statutes and whistleblower protections and penalties. The State of Wisconsin does not have a false claims law.

The Federal False Claims Act can be found in the United States Code in sections 3729-3733. The Federal False Claims Act is a statute that imposes civil liability of between $5,500 and $11,000 per claim, plus three times the amount of damages sustained by the government as a result of the violation of this statute, to any person or entity who:

  • Knowingly submits a false claim to the federal government for payment
  • Knowingly makes or uses a false record or statement to obtain payment or approval of a claim by the federal government
  • Uses a false statement to decrease an obligation to the government

Under the qui tam (whistleblower) provisions of the False Claims Act, private citizens with knowledge of potential violations may file suit on behalf of the government. A private citizen must be an original source who has direct and independent knowledge of the information on which the allegations are based and has voluntarily provided the information to the government before filing an action.

If the government proceeds with the suit, the government will have primary responsibility for prosecution and the private citizen will have the right to be a party to the suit. In this case, the private citizen would be entitled to receive a portion of the proceeds of the suit or a settlement, ranging from 15-25 percent.

If the government chooses to not proceed with prosecuting the action under the False Claims Act, the private citizen will have the right to proceed with a case on their own. In this case, the private citizen would be entitled to 25-30 percent of the proceeds of the action or settlement.

The False Claims Act provides protection and relief to any employee who is discharged, demoted, suspended, threatened, harassed, or incurs any discrimination in the terms and conditions of employment because of bringing the action. The relief includes reinstatement with the same seniority status they would have had prior to the discrimination, twice the amount of back pay and compensation for any special damages sustained including litigation and reasonable attorneys' costs.

Children's Hospital has issued "Our Code of Business Conduct." Any interested party can obtain a copy by calling the director of Corporate Compliance at (414) 266-2215.

There is also a compliance helpline available to anyone report any suspected or observed non-compliant activities. The reporting of suspected or observed non-compliant activities can be accomplished by:

  • Asking the receptionist for a meeting with the director of Corporate Compliance, who is located in C760 of Children's Corporate Center
  • Calling the director Corporate Compliance at (414) 266-2215
  • Sending an e-mail to the director of Corporate Compliance at TTwinem@chw.org
  • Calling the Ethicspoint hotline at (414) 266-1773 or (877) 659-5200
  • Accessing the Ethicspoint hotline at www.Ethicspoint.com and entering Children's Hospital as the name of the institution