False Claims Laws & Hilltop Compliance

The Federal False Claims Act (FCA) (31 U.S.C. §§ 3729–3733) and related state laws make it illegal to knowingly submit or cause the submission of false or fraudulent claims for payment to the United States Government, including claims for services provided for Medicaid or other federal and state-administered health care programs.

Hilltop is committed to full compliance with all federal and state requirements, including:

Federal False Claims Act (31 U.S.C. §§ 3729–3733)

• Prohibits knowingly submitting, or causing to be submitted, false or fraudulent claims in applications for benefits or payments.
• Allows individuals (known as whistleblowers or relators) to bring actions on behalf of the government and share in any recovery.
• Provides protection against retaliation for those who report suspected violations.
• Violations can result in civil penalties, treble (triple) damages, and possible criminal prosecution.

Administrative Remedies for False Claims and Statements (31 U.S.C. Chapter 38)

• Establishes civil penalties for false statements and claims made to federal agencies.

Colorado Law (Colorado Medicaid False Claims Act, C.R.S. § 25.5-4-303.5 et seq.)

• State law prohibits making or causing to be made any false statement, representation, or claim to obtain or retain payments from state-administered health care programs, including Medicaid.
• Civil and criminal penalties may apply.

Any person or organization found to have violated these laws may face significant penalties, such as civil fines, treble (triple) damages, and possible criminal prosecution.

Prevention of Fraud, Waste, and Abuse

Hilltop maintains strong internal controls to prevent and detect fraud, waste, and abuse, including:

• Clear policies and defined procedures for operational and financial processes.
• Separation of duties and multiple levels of approval.
• Regular audits, data analysis, and risk assessments.
• Education and training to help employees recognize and report potential fraud, waste, or abuse.

Employee, Contractor, and Agent Responsibility

All employees, contractors, and agents have a responsibility, and are expected, to report any concerns about potential fraud, waste, or abuse immediately.

Concerns may be reported by:

• Speaking with a supervisor, Program Director, or People Operations Business Partner.
• Contacting Hilltop’s Ethics Officer (or submitting an Employee Concern Form on the Hilltoppers home page).
• Contacting Hilltop’s Compliance Officer.
• Emailing the Vice Chair of the Board of Directors at boardethics@htop.org.
• Reporting concerns directly to the appropriate state or federal agencies, if preferred.

For more details about anonymity, confidentiality, and investigation procedures, see “Protected Disclosure and Whistleblower Policy.”