AIM prevents and detects fraud, waste, and abuse through an extensive compliance program, compliance training; accurate service documentation, coding, billing, and timekeeping requirements; exclusion screening; monitoring and auditing; confidential reporting channels; investigation of reported concerns; prompt correction of identified errors; and timely reporting, return, and explanation of identified overpayments as required by law. Employees, contractors, and agents must cooperate with these controls and promptly report suspected violations.

This policy explains prohibited conduct, reporting responsibilities, whistleblower protections, and the federal and New York laws that support AIM’s compliance program. Employees, contractors, and agents must promptly report suspected false claims, inaccurate documentation, overpayments, or other compliance concerns through AIM’s reporting channels.

The federal False Claims Act prohibits knowingly submitting or causing a false claim for government payment, using a false record or statement that is material to a claim, conspiring to violate the Act, or knowingly concealing or improperly avoiding an obligation to repay the government. Knowingly includes actual knowledge, deliberate ignorance, and reckless disregard; proof of a specific intent to defraud is not required. Violations may result in three times the government's damages plus an inflation-adjusted civil penalty for each claim. Private individuals may bring qui tam actions on the government's behalf and may receive a share of the recovery.

Examples of prohibited conduct include billing for services not provided, using documentation known to be false or materially incomplete to support payment, and knowingly retaining an overpayment that must be returned. Employees must report suspected conduct even when they are uncertain whether it legally constitutes a false claim.

Examples of prohibited conduct include billing for services not provided; using records known to be false or materially incomplete to obtain payment; misrepresenting compliance with contractual or regulatory requirements; and knowingly concealing or retaining an overpayment that must be returned. Employees must report suspected conduct even when they are uncertain whether it legally constitutes a false claim.

In addition to government enforcement, the federal False Claims Act permits a private person, known as a qui tam relator, to file an action on behalf of the United States. If the action results in a recovery, the relator may receive a share of the proceeds as provided by law.

The amount awarded to a successful qui tam relator is determined under the federal False Claims Act and depends in part on whether the government intervenes and the relator's contribution to the action.

The federal Program Fraud Civil Remedies Act allows a federal agency to pursue administrative penalties and assessments when a person knowingly submits a false claim or written statement to the agency. Liability may arise when the claim is submitted, even if it is not paid, and the agency—not a federal court—initially determines liability and the applicable remedy.

Administrative remedies may apply when a false claim or statement is submitted even if the government does not pay it. The federal agency responsible initially determines liability and the available penalties or assessments, subject to applicable review procedures.

The New York False Claims Act, State Finance Law §§ 187–194, and related New York laws impose