Health Share of Oregon Compliance Program Self Assessment Tool
|
|
- Rhoda Ward
- 7 years ago
- Views:
Transcription
1 Health Share of Oregon Compliance Program Self Assessment Tool Name of Organization: Person Completing Assessment: Date Assessment Completed: Title: 1. Written Policies and Procedures 1.1 Are compliance expectations included in a written code of conduct or code of ethics? 1.2 Has the compliance program been implemented within the organization? 1.3 Does the compliance program provide guidance to employees and others associated with the Delegate on how to identify and communicate compliance issues to compliance personnel? 1.4 Does the compliance program describe how potential compliance problems are investigated and resolved? 1.5 Does the compliance program clearly communicate the Delegate s compliance expectations to the governing board, management, employees and others associated with the Delegate? 1.6 Have the compliance program and its associated policies and procedures been reviewed and approved by the governing board or senior management? 1.7 Is the compliance program made accessible to the governing board, senior management, employees, customers and others associated with the Delegate? Page 1 of 9
2 2. Designate an employee vested with responsibility 2.1 Is the responsible compliance position an employed position? 2.2 Does the responsible compliance position have responsibility for day to day operation of the compliance program? 2.3 Does the person with responsibility for the day to day operation of the compliance program have responsibilities other than compliance? 2.4 If the answer to question 2.3 is Yes, are sufficient resources made available to the person with responsibility for the day to day operation of the compliance program to satisfactorily carry out their compliance activities? What evidence exists to demonstrate that the Compliance Officer is conducting his/her compliance activities satisfactorily? 2.5 Does the responsible compliance position report to the CEO or other senior staff (and not through the legal dept or the CFO)? 2.6 Does the responsible compliance position periodically communicate with the governing board on the activities of the compliance program? 2.7 Does the responsible compliance position have a regularly pre-scheduled meeting with the governing board to report on activities of the compliance program? 2.8 Is the responsible compliance position part of the Delegate s leadership? 2.9 Does the person with responsibility for the day to day operation of the compliance program have a background in compliance? Page 2 of 9
3 2.10 Has the Delegate created compliance committees at both the management and governing body levels? 3. Training and education 3.1 Is there evidence of a compliance training program which includes the Code of Conduct/Ethics; expectations of the compliance program; and how the compliance program operates? 3.2 Are new employees, board members and affiliated trained in compliance so that they could identify circumstances of fraud, waste and abuse? 3.3 Is the compliance training made part of orientation for new employees, board members and affiliates? 3.4 Is there annual training on compliance to employees, board members and affiliates so that they could identify circumstances of fraud, waste and abuse? 3.5 If a compliance issue arises that appears to be systemic or broad-based, is there a specific compliance related training performed to address the specific issue? 3.6 Do training materials include information identifying the responsible compliance position; their contact information; anonymous and confidential methods to report potential compliance violations and ways to obtain additional assistance? 3.7 Is the training information made accessible throughout the organization? 3.8 Is training provided by qualified individuals or entities? Page 3 of 9
4 4. Communication lines to the responsible compliance position 4.1 Are there accessible mechanism(s) for the governing board, management, employees and others associated with the Delegate to communicate compliance related concerns to the responsible compliance position? Provide examples 4.2 Do the accessible mechanism referred to in 4.1 include methods for anonymous or confidential communication? 4.3 Are the available lines of communication and examples of the types of issues to be reported to the responsible compliance position well publicized throughout the Delegate(e.g. orientation/education sessions, posters, pamphlets, intra/internet, etc)? 4.4 Does the entity maintain a tracking system for all questions or concerns that come to the responsible compliance position? 4.5 Does a mechanism exist for providing feedback to those that raise questions/concerns (even those communicated on an anonymous or confidential basis)? 5. Disciplinary policies to encourage good faith participation 5.1 Do disciplinary policies exist which encourage good faith participation in the compliance program by the governing board, senior management, Page 4 of 9
5 employees and others associated with the Delegate? 5.2 Do disciplinary policies set out expectations for reporting compliance issues and for assisting in their resolution? 5.3 Do disciplinary policies outline sanctions for failing to report suspected problems; participating in on-compliant behavior or encouraging, directing, facilitating or permitting non-compliant behavior? 5.4 If any disciplinary action was taken, was discipline fairly and consistently applied regardless of the perpetrator s position with the Delegate? 5.5 Have disciplinary policies and procedures related to the compliance program been implemented, published and communicated to the governing board, senior management, employees and others associated with the Delegate? 5.6 Is there a stated consequence for assisting, participating, facilitating in or ignoring a breach of the Delegate s compliance program? 5.7 Is there a stated consequence for assisting participating facilitating in, or ignoring fraud, waste, or abuse in the Delegate program? 6. A system for routing identification of compliance risk areas 6.1 Does a system exist within the Delegate s compliance plan to routinely identify compliance risk areas specific to the type of service provided? 6.2 Does a system exist within the Delegate compliance plan to routinely conduct selfevaluation of risk areas, including internal audits and as appropriate external audits? 6.3 Does the Delegate routinely Page 5 of 9
6 evaluate potential or actual noncompliance as a result of its selfevaluations and audits? 6.4 Does the Delegate have systems in place to ensure that its employees, contractors, grantees and other organizations providing services or billings through the Delegate are not submitting false claims as that may be defined under the federal False Claims Act? 6.5 Does the Delegate have a formal committee that assists the compliance officer in identifying risk areas and evaluating potential or actual noncompliance as part of a risk evaluation process? 6.6 If the answer to 6.4 is yes, does the committee referenced in 6.4 have regular meetings where meeting summaries are prepared or minutes are taken and reports are issued to the Delegate s management or governing board that routinely identify risk areas for the organization. 6.7 Has the Delegate identified its compliance risks to minimize its risk exposure, address weaknesses in the compliance program and correct violations of the Delegate s program s requirements? 6.8 Does the Delegate analyze the effectiveness of corrective actions identified in the risk analysis, in previous audits (e.g. billing for excluded parties, disclosure requirements for overpayments required by the federal Patient Protection and Affordable Care Act or third party zero billings)? 6.9 The federal Deficit Reduction Act of 2005 requires Medicaid providers that receive $5million or more in Medicaid payments during a federal fiscal year to certify that it has established written policies and procedures informing their employees, contractors and agents about Page 6 of 9
7 federal and state false claim acts and whistleblower protections. Has the Delegate provider met DRA s requirement? 7. A system for responding to compliance issues 7.1 Does a system exist within the Delegate compliance plan for responding to compliance issues as they are raised? 7.2 Does a system exist within the Delegate compliance plan for investigating potential compliance issues? 7.3 Does a system exist within the Delegate s compliance plan to respond to compliance issues that are identified in the course of self-evaluation and audits? 7.4 Does a system exist within the Delegate to correct compliance issues promptly and thoroughly and implement procedures, policies and systems that may be necessary to reduce the potential for recurrence? 7.5 Does a system or methodology exist to periodically prioritize compliance oversight of activities that are the most serious or most likely to occur? 7.6 Does a system exist within the Delegate s compliance plan for identifying and reporting compliance issues to Health Share and OHA? 7.7 Does a system exist within the Delegate s compliance plan to report, refund and explain overpayments received? 7.8 Do the Delegate s policies and procedures ensure immediate action to secure the health and safety of current enrollees, including those situations where a failure in compliance has occurred? Provide details on how the Page 7 of 9
8 system works. 7.9 Has the system for responding to compliance issues been used by employees, management, the governing board or affiliates? What are the details on how the system works? 7.10 Did the Delegate respond to issues on potential overpayments made which may include, but not be limited to: billing for DOS for enrollees after enrollee s date of death; checking the 3 lists for individuals who are excluded from providing, ordering or billing for services under the Medicaid program; mandatory disclosure, repayment and explanation of overpayments received under the Medicaid program as required by Section 6402 of the PPACA; and billing for services while the enrollee was in an alternative level of care that would be inconsistent with the service being billed. 8. A policy of non-intimidation and non-retaliation 8.1 Does the compliance plan or Delegate policy state intimidation or retaliation will not be permitted against individuals who in good faith participate in the compliance program, including but not limited to reporting potential issues, investigating issues, selfevaluation, audits and remedial actions and reporting to appropriate officials? 8.2 Are allegations of intimidation or retaliation fully and completely investigated? What history exists associated with investigations of allegations of intimidation or Page 8 of 9
9 retaliation? 8.3 Is the disciplinary action uniformly and consistently applied across the organization regardless of title or position? What examples exist of uniform application of discipline? Formulated: February 2013 Page 9 of 9
Frequently Asked Questions
From the New York State Office of the Medicaid Inspector General Web site at www.omig.ny.gov/data/content/view/261/53, last accessed on January 27, 2012 Mandatory Provider Compliance Programs Frequently
More informationMedical Answering Services, Medicaid Compliance Program Overview. Dated December 1, 2012
Medical Answering Services, Medicaid Compliance Program Overview Dated December 1, 2012 Medical Answering Services, LLC (MAS) has implemented and maintains a Compliance Program with all required elements
More informationCompliance Requirements for Healthcare Carriers
INFORMATION DRIVES SOUND ANALYSIS, INSIGHT REGULATORY COMPLIANCE ADVISORY Compliance Requirements for Healthcare Carriers Introduction With the introduction of the new healthcare exchanges in January 2014
More informationVCU HEALTH SYSTEM Compliance Program. Updated August 2015
VCU HEALTH SYSTEM Compliance Program Updated August 2015 Table of Contents Section I. Purpose of the Compliance Program... 3 Section II. Elements of an Effective Compliance Program... 3 A. Written Policies
More informationTitle: False Claims Act & Whistleblower Protection Information and Education
Care Initiatives Policy and Procedure Title: False Claims Act & Whistleblower Protection Information and Education Version Number Implemented By Revision Date Approved By Approval Date Initial Compliance
More informationFraud, Waste and Abuse Page 1 of 9
Page 1 of 9 Overview It is the policy of MVP Health Care, Inc. and its affiliates (collectively referred to as MVP ) to comply with all applicable federal and state laws regarding fraud, waste and abuse.
More informationONEIDA HEALTHCARE S CORPORATE COMPLIANCE PROGRAM
ONEIDA HEALTHCARE S CORPORATE COMPLIANCE PROGRAM Sept 2002 Revised December 2009 521 provisions Reviewed/revised: December 2012 1 Under Health Reform Law and as a condition of enrollment in Medicare and
More informationFalse Claims and Whistleblower Protections All employees, volunteers, students, physicians, vendors and contractors
Policy and Procedure Title: Applies to: False Claims and Whistleblower Protections All employees, volunteers, students, physicians, vendors and contractors Number: First Created: 1/07 SY-CO-019 Issuing
More information2012-2013 MEDICARE COMPLIANCE TRAINING EMPLOYEES & FDR S. 2012 Revised
2012-2013 MEDICARE COMPLIANCE TRAINING EMPLOYEES & FDR S 2012 Revised 1 Introduction CMS Requirements As of January 1, 2011, Federal Regulations require that Medicare Advantage Organizations (MAOs) and
More informationCompliance Training for Medicare Programs Version 1.0 2/22/2013
Compliance Training for Medicare Programs Version 1.0 2/22/2013 Independence Blue Cross is an independent licensee of the Blue Cross and Blue Shield Association. 1 The Compliance Program Setting standards
More informationFraud, Waste and Abuse Prevention and Education Policy
Corporate Compliance Fraud, Waste and Abuse Prevention and Education Policy The Compliance Program at the Cortland Regional Medical Center (CRMC) demonstrates our commitment to uphold all federal and state
More informationMedicare Compliance Program Effectiveness Training - Table of Contents Overview
Medicare Compliance Program Effectiveness Training Care1st Compliance Department Calendar Year 2012 1 Table of Contents Overview Compliance Program Requirements Why are the Compliance Program Requirements
More informationMental Health Resources, Inc. Mental Health Resources, Inc. Corporate Compliance Plan Corporate Compliance Plan
Mental Health Resources, Inc. Mental Health Resources, Inc. Corporate Compliance Plan Corporate Compliance Plan Adopted: January 2, 2007 Revised by Board of Directors on September 4, 2007 Revised and Amended
More informationLUZERNE/SCHUYLKILL WORKFORCE INVESTMENT BOARD CORPORATE COMPLIANCE/ETHICS PLAN
LUZERNE/SCHUYLKILL WORKFORCE INVESTMENT BOARD CORPORATE COMPLIANCE/ETHICS PLAN It is the philosophy of the Luzerne/Schuylkill Workforce Investment Board that all of its employees will comply with all applicable
More informationMEDICAID COMPLIANCE POLICY
6232 MEDICAID COMPLIANCE POLICY It is the policy of the Board of Education that all school district s practices regarding Medicaid claims for services be in compliance with all applicable federal and state
More informationThey re Not For the Faint of Heart Christine Rinn Chandra Westergaard
Medicare Advantage and Part D They re Not For the Faint of Heart Christine Rinn Chandra Westergaard Introduction Changes to the Medicare Advantage and Part D programs may make participation less attractive
More informationPOUGHKEEPSIE CITY SCHOOL DISTRICT PUPIL PERSONNEL DEPARTMENT S MEDICAID BILLING COMPLIANCE PROGRAM AND PROCEDURES
POUGHKEEPSIE CITY SCHOOL DISTRICT PUPIL PERSONNEL DEPARTMENT S MEDICAID BILLING COMPLIANCE PROGRAM AND PROCEDURES INTRODUCTION This Poughkeepsie City School District Medicaid Billing Compliance Program
More informationThis policy applies to UNTHSC employees, volunteers, contractors and agents.
Policies of the University of North Texas Health Science Center 3.102 Detecting and Responding to Fraud, Waste and Abuse Chapter 3 Compliance Policy Statement UNTHSC developed and implemented a Compliance
More informationCorporate Compliance and Ethics
Corporate Compliance and Ethics Title: Corporate Compliance and Ethics Course Code: EL-CCE-COMP-0 Course Outline Section 1: Introduction A. Course Contributors B. About This Course C. Learning Objectives
More informationReports of Compliance Concerns and Violations
The University of Chicago Medical Center Compliance Manual (UCHHS;BSD;UCPP) Reports of Compliance Concerns and Violations Issued: November 1, 1999 Reports of Compliance Concerns and Violations Revised:
More informationCENTER FOR INSTRUCTION TECHNOLOGY AND INNOVATION (CiTi) MEDICAID BILLING COMPLIANCE PROGRAM
CENTER FOR INSTRUCTION TECHNOLOGY AND INNOVATION (CiTi) MEDICAID BILLING COMPLIANCE PROGRAM INTRODUCTION This Program is an integral part of the CiTi s ongoing efforts to achieve compliance with federal
More informationApproved by the Audit and Compliance Committee of the Providence Health & Services Board of Directors
Integrity and Compliance Description Approved by the Audit Committee of the Providence Health & Services Board of Directors December 7, 2009 Contents: Introduction Page 1 Purpose Page 2 Compliance Administration
More informationADMINISTRATIVE MANUAL Subject: CORPORATE RESPONSIBILITY 21.49. Directive #: 21.49 Present Date: January 2011
Page: 1 of 18 Directive #: 21.49 Present Date: January 2011 Original Date: September 2004 Review Date: January 2013 Applicable To: SVHC & Affiliated Companies SVMC SCLM SLH FCPC POLICY In furtherance of
More informationE Distribution: GENERAL POLICY ISSUES. Agenda item 4 WFP ANTI-FRAUD AND ANTI-CORRUPTION POLICY. For approval
Executive Board Second Regular Session Rome, 8 11 November 2010 POLICY ISSUES Agenda item 4 For approval WFP ANTI-FRAUD AND ANTI-CORRUPTION POLICY E Distribution: GENERAL WFP/EB.2/2010/4-C/1 29 September
More informationFalse Claims Act Policy 650-117 Effective Date 01/01/2007 Compliance Manual
False Claims Act Policy 650-117 POLICY Monroe County Healthcare Authority is committed to the highest possible standards of ethical, moral and legal business conduct. Prevention of health care fraud, waste
More informationPOLICY AND PROCEDURES MANUAL FRAUD, WASTE, AND ABUSE
Page Number: 1 of 7 TITLE: PURPOSE: FRAUD, WASTE, AND ABUSE The Harris County Hospital District implemented a Corporate Compliance Program in an effort to establish effective internal controls that promote
More informationCompliance Programs for Physician Practices
Compliance Programs for Physician Practices Timothy P. Blanchard, MHA, JD AAPC 2011 National Conference April 5, 2011 2011 Blanchard Manning LLP. Session Topics Changes in the Regulatory Environment 7
More informationATTACHMENT I-A MEDICARE ADVANTAGE AND PRESCRIPTION DRUG COMPLIANCE PROGRAM EFFECTIVENESS SELF- ASSESSMENT QUESTIONNAIRE (SAQ)
Name of Sponsoring Organization: MA-PD/PDP Contract Numbers: Name/Title of Person Completing Assessment: Date of Assessment: (Rev. 5. 10-2015) Note: Sponsoring Organizations should not interpret every
More informationMEMORANDUM. 2. Public Health Solutions responds to questions and reports of fraud, waste, and abuse quickly.
MEMORANDUM To: Public Health Solutions staff providing Medicaid reimbursable services From: Jane Levine, Vice-President/General Counsel Re: Preventing Medicaid Fraud Summary of Public Health Solutions
More informationIMMUNOTEC INC. AUDIT AND DISCLOSURE POLICY MANAGEMENT COMMITTEE CHARTER AND WHISTLEBLOWER POLICY
IMMUNOTEC INC. AUDIT AND DISCLOSURE POLICY MANAGEMENT COMMITTEE CHARTER AND WHISTLEBLOWER POLICY ORGANIZATION There shall be a committee of the Board of Directors of the Corporation (the Board ) to be
More informationTITLE: Scripps Compliance Program
PAGE 1 of 7 TITLE: Scripps Compliance Program IDENTIFIER: S-FW-LD-1003 APPROVED: Executive Cabinet 08/14/12 ORIGINAL FORMULATION: 11/00 REVISED: 02/06, 11/06, 10/09, 08/12 REVIEWED: EFFECTIVE: Acute Care:
More informationCompliance Plan False Claims Act & Whistleblower Provisions Purpose/Policy/Procedures
CATHOLIC CHARITIES OF THE ROMAN CATHOLIC DIOCESE OF SYRACUSE, NY and TOOMEY RESIDENTIAL AND COMMUNITY SERVICES Compliance Plan False Claims Act & Whistleblower Provisions Purpose/Policy/Procedures Purpose:
More informationPOLICY SUBJECT: EFFECTIVE DATE: 5/31/2013. To be reviewed at least annually by the Ethics & Compliance Committee COMPLIANCE PLAN OVERVIEW
Compliance Policy Number 1 POLICY SUBJECT: EFFECTIVE DATE: 5/31/2013 Compliance Plan To be reviewed at least annually by the Ethics & Compliance Committee COMPLIANCE PLAN OVERVIEW Sound Inpatient Physicians,
More informationCORPORATE COMPLIANCE: BILLING & CODING COMPLIANCE
SUBJECT: CORPORATE COMPLIANCE: BILLING & CODING COMPLIANCE MISSION: Quality, honesty and integrity, in everything we do, are important values to all of us who are associated with ENTITY NAME ( ENTITY NAME
More informationFraud, Waste and Abuse: Compliance Program. Section 4: National Provider Network Handbook
Fraud, Waste and Abuse: Compliance Program Section 4: National Provider Network Handbook December 2015 2 Our Philosophy Magellan takes provider fraud, waste and abuse We engage in considerable efforts
More informationSample Healthcare Compliance Program
P.O. Box 153 Shell, WY 82441 307-765-2241 (direct) 888-286-2095 (e-fax) info@hcma-consulting.com www.hcma-consulting.com Sample Healthcare Compliance Program 1. Introduction COMPANY is committed to establishing
More informationAlliance for Better Health Care, LLC
Alliance for Better Health Care, LLC ORGANIZATIONAL POLICY FALSE CLAIMS ACT AND WHISTLEBLOWER PROVISIONS Page 1 of 5 EFFECTIVE DATE: NUMBER: March 2015 ORIGINATOR: Corporate Compliance Officer CONCURRENCE:
More informationCOMPLIANCE PROGRAM AND COMPLIANCE CODE OF CONDUCT
COMPLIANCE PROGRAM AND COMPLIANCE CODE OF CONDUCT I. COMPLIANCE PROGRAM IN GENERAL A. MISSION. B. PURPOSE. It is the mission of My Choice Family Care ( MCFC ) to respect the dignity and personal autonomy
More informationIntegrity. Providence Integrity and Compliance Program Description
Integrity and Compliance Description Approved by the Audit Committee of the Providence Health & Services Board of Directors December 9, 2014 Contents: Introduction Page 1 Purpose Page 2 Compliance Administration
More informationDeficit Reduction Act Information for Employees, Contractors and Agents
Nationally Ranked. Locally Trusted. Denver Health Deficit Reduction Act Information for Employees, Contractors and Agents EFFECTIVE DATE: DECEMBER 31, 2006 PAGE 1 OF 5 Purpose: Provide a written policy
More informationCORPORATE COMPLIANCE POLICY AND PROCEDURE
Title: Fraud Waste and Abuse Laws in Health Care Policy # 1011 Sponsor: Corporate Compliance Approved by: Carleen Dunne, Director, Corporate Compliance and Privacy Officer Issued: Page: 1 of 7 June 25,
More informationHPC Healthcare, Inc. Administrative/Operational Policy and Procedure Manual
Operational and Procedure Manual 1 of 7 Subject: Corporate Compliance Plan Originating Department Quality & Compliance Effective Date 1/99 Administrative Approval Review/Revision Date(s) 6/00, 11/99, 2/02,
More informationHope In-Home Care CODE OF CONDUCT AND ETHICS
Hope In-Home Care CODE OF CONDUCT AND ETHICS September 2014 Table of Contents A MESSAGE FROM OUR DIRECTOR... 3 INTRODUCTION TO THE CODE OF CONDUCT AND ETHICS... 4 ELEMENT 1: QUALITY OF CARE... 5 ELEMENT
More informationI. Policy Purpose. II. Policy Statement. III. Policy Definitions: RESPONSIBILITY:
POLICY NAME: POLICY SPONSOR: FRAUD, WASTE AND ABUSE COMPLIANCE OFFICER RESPONSIBILITY: EFFECTIVE DATE: REVIEW/ REVISED DATE: I. Policy Purpose The purpose of this policy is to outline the requirements
More informationCOMPLIANCE PROGRAM FOR XL GROUP PLC
1 COMPLIANCE PROGRAM FOR XL GROUP PLC I. PURPOSE The purpose of the XL Group plc Compliance Program (the Program ) is to (a) help protect XL Group plc companies from financial or reputational harm that
More informationPOLICY 4.2.9 INVESTIGATIONS OF LEGAL AND ETHICAL MISCONDUCT
I. POLICY A. This policy applies to all investigations by CB Richard Ellis, Inc., referred to herein as CBRE or the Company, of allegations or occurrences of legal and ethical misconduct (including fraud)
More informationMedical Transportation Compliance. Mandated Compliance Guidance
2 0 Medical Transportation Compliance 1 1 Mandated Compliance Guidance NY State Medicaid Office of Inspector General (OMIG) has mandated compliance for providers with a $500,000 threshold of Medicaid revenue
More informationpolicy (C) Deficit Reduction Act of 2005 and the Federal False Claims Act
Name of Policy: Detecting and Preventing Fraud, Waste and Abuse Policy Number: 3364-15-02 Issuing Office: President Responsible Agent: Compliance/Privacy Officer Revision date: July 5, 2011 Original effective
More informationMetropolitan Jewish Health System and its Participating Agencies and Programs [MJHS]
Metropolitan Jewish Health System and its Participating Agencies and Programs [MJHS] POLICY PURSUANT TO THE FEDERAL DEFICIT REDUCTION ACT OF 2005: Detection and Prevention of Fraud, Waste, and Abuse and
More informationADMINISTRATIVE POLICY SECTION: CORPORATE COMPLIANCE Revised Date: 2/26/15 TITLE: FALSE CLAIMS ACT & WHISTLEBLOWER PROVISIONS
Corporate Compliance Plan AD-819-0 Reporting of Compliance Concerns & Non-retaliation AD-807-0 Compliance Training Policy CFC ADMINISTRATIVE POLICY AD-819-1 SECTION: CORPORATE COMPLIANCE Revised Date:
More informationCODE OF ETHICS FOR SENIOR FINANCIAL OFFICERS
CODE OF ETHICS FOR SENIOR FINANCIAL OFFICERS Statement of Principle Our long-standing policy, as stated in our Pledge, is to maintain the highest standard of moral and ethical behavior in our relationships
More informationSupporting Effective Compliance Programs
October 2015 Supporting Effective Compliance Programs The Oversight Roles of the Board Audit and Risk Committees in Regulatory Compliance By Paul Osborne, CPA, CAMS, AMLP, and Peggy Sepp, CIA To be effective,
More informationHealth Sciences Compliance Plan
INDIANA UNIVERSITY Health Sciences Compliance Plan 12.18.2014 approved by University Clinical Affairs Council Table of Contents Health Sciences Compliance Plan I. INTRODUCTION... 2 II. SCOPE... 2 III.
More informationFraud/Abuse and False Claims Act Compliance Education for Providers, Contractors, and Vendors. Presented by: by: Compliance Department
Fraud/Abuse and False Claims Act Compliance Education for Providers, Contractors, and Vendors Presented by: by: Compliance Department 6/26/2013 Purpose Welcome to JHHC Corporate Compliance Training Program
More informationCOUNTY OF ORANGE DEPARTMENT OF HEALTH. Corporate Compliance Plan
COUNTY OF ORANGE DEPARTMENT OF HEALTH Corporate Compliance Plan COUNTY OF ORANGE DEPARTMENT OF HEALTH CORPORATE COMPLIANCE PLAN I. Corporate Compliance Plan It is the policy of the Orange County Department
More informationIntroductions. Today s Topics 10/12/2015
Healthcare Enforcement Compliance Institute Tuesday, October 7, 2015 Laubach/Waltz HCCA October 2015 1 Introductions Judy Waltz Lori Laubach 2 Today s Topics Identifying the need for auditing (and refunds)
More informationMEMORIAL HERMANN HEALTH SYSTEM POLICY
Page 1 of 5 MEMORIAL HERMANN HEALTH SYSTEM POLICY POLICY TITLE: False Claims Policy PUBLICATION DATE: 05/23/2014 VERSION: 2 POLICY PURPOSE: To comply with certain requirements set forth in the Deficit
More informationFWA Program. Program Description. Issued by: Regulatory Compliance Department
FWA Program Program Description Issued by: Regulatory Compliance Department July 2016 2016 FWA Program Description Page 1 of 16 Table of Contents Introduction Introduction..3 Definitions 4 Examples..6
More informationCAYUGA COUNTY HEALTH DEPARTMENT CORPORATE COMPLIANCE PLAN
CAYUGA COUNTY HEALTH DEPARTMENT CORPORATE COMPLIANCE PLAN CAYUGA COUNTY HEALTH DEPARTMENT CORPORATE COMPLIANCE PLAN TABLE OF CONTENTS Page I. Introduction...1 A. Overview...1 B. The Program s Elements...2
More informationCorporate Compliance and Ethics Program Effective as adopted on February 21, 2012
Corporate Compliance and Ethics Program Effective as adopted on February 21, 2012 Page 1 of 7 SECTION 1. STATEMENT OF INTENT As a specialty pharmaceutical company and diagnostic laboratory, Prometheus
More informationPHI Air Medical, L.L.C. Compliance Plan
Page No. 1 of 13 Introduction: The PHI Air Medical, L.L.C. is to be used by employees, contractors and vendors to get a high level understanding of the key regulatory requirements relating to our participation
More informationVNSNY CORPORATE. DRA Policy
VNSNY CORPORATE DRA Policy TITLE: FEDERAL DEFICIT REDUCTION ACT OF 2005: POLICY REGARDING THE DETECTION & PREVENTION OF FRAUD, WASTE AND ABUSE AND APPLICABLE FEDERAL AND STATE LAWS APPLIES TO: VNSNY ENTITIES
More informationIMAX CORPORATION PROTOCOL FOR REPORTING SUSPECTED VIOLATIONS OF THE IMAX CODE OF ETHICS. (Whistle Blower Program)
IMAX CORPORATION PROTOCOL FOR REPORTING SUSPECTED VIOLATIONS OF THE IMAX CODE OF ETHICS (Whistle Blower Program) November 2004 (updated February 2012) PROTOCOL FOR REPORTING SUSPECTED VIOLATIONS OF THE
More informationFraud, Waste and Abuse Prevention Training
Fraud, Waste and Abuse Prevention Training The Centers for Medicare & Medicaid Services (CMS) requires annual fraud, waste and abuse training for organizations providing health services to MA or Medicare
More informationHUNTERDON HEALTHCARE SYSTEM ADMINISTRATIVE POLICY AND PROCEDURE MANUAL
Page 1 of 12 Subcategory: I. POLICY It is the policy of Hunterdon Healthcare System (HHS) to be in compliance with all applicable federal and state laws, to enforce procedures designed to detect and prevent
More informationEstablishing An Effective Corporate Compliance Program Joan Feldman, Esq. Vincenzo Carannante, Esq. William Roberts, Esq.
Establishing An Effective Corporate Compliance Program Joan Feldman, Esq. Vincenzo Carannante, Esq. William Roberts, Esq. November 11, 2014 Shipman & Goodwin LLP 2014. All rights reserved. HARTFORD STAMFORD
More information* SAMPLE * COMPLIANCE PROGRAM GROUP PRACTICE
[NOTE: This is a sample compliance plan based on OIG Compliance Program Guidance. Groups should modify it as appropriate to fit their circumstances] * SAMPLE * COMPLIANCE PROGRAM GROUP PRACTICE (Revised
More informationPINE VALLEY HEALTHCARE & REHABILITATION CENTER. Corporate Compliance Plan. 10843655v5
PINE VALLEY HEALTHCARE & REHABILITATION CENTER Corporate Compliance Plan CORPORATE COMPLIANCE PLAN TABLE OF CONTENTS Page I. DEFINITIONS...1 II. INTRODUCTION...2 III. COMPLIANCE RESPONSIBILITIES AND OVERSIGHT...3
More informationFederal False Claims Act (31 USC 3729 through 3733)
I. INTRODUCTION The False Claims Act (FCA) is a federal law that was created to discourage and punish profiteers from providing sub-standard supplies to the Union Army during the Civil War. The FCA was
More informationEssentials Elements of an Effective Ethics Compliance Program Submitted to Senate- Government Operations Committee January 26, 2016
Madeline M. Motta MS, JD, JSD Corporate Compliance Ethics Professional Essentials Elements of an Effective Ethics Compliance Program Submitted to Senate- Government Operations Committee January 26, 2016
More informationResolution No. 254 September 9, 2009. Adopting A Whistleblower Employee/Agent Protection Policy For Ulster County Employees/Agents
The Administrative Services Committee (Chairman Provenzano and Legislators Hochberg, Lomita, Terpening, Hansut, Petit and Ronk) and the Human Development and Personnel Committee (Chairman Gregorius and
More informationSTATEMENT FROM THE CHAIRMAN
STATEMENT FROM THE CHAIRMAN In an ever-changing global marketplace, it is important for all of us to have an understanding of the responsibilities each of have in carrying out day-to-day business decisions
More informationFEDERAL AND STATE FALSE CLAIMS ACT, ADMINISTRATIVE PENALTIES AND WHISTLEBLOWER PROTECTION LAWS:
Corporate Compliance Fraud, Waste, Abuse and Whistleblower Education The Compliance Program at Cortland Regional Medical Center (CRMC) demonstrates our commitment to uphold all federal and state laws and
More informationCORPORATE COMPLIANCE POLICY AND PROCEDURE
Title: Fraud, Waste, or Abuse (Whistleblower) Policy Policy # 1010 Sponsor: Corporate Approved by: Carleen Dunne, Director, Corporate and Privacy Officer Issued: Page: 1 of 6 June 25, 2007 Last Reviewed/Updated
More informationSCAN Health Plan Policy and Procedure Number: CRP-0067, False Claims Act & Deficit Reduction Act 2005
Health Plan Policy and Procedure Number: CRP-0067, False Claims Act & Deficit Reduction Act 2005 Approver Approval Stage Date Chris Zorn Approval Event (Authoring) 12/09/2013 Nancy Monk Approval Event
More informationMEAD JOHNSON NUTRITION COMPANY CODE OF ETHICS FOR SENIOR FINANCIAL OFFICERS
MEAD JOHNSON NUTRITION COMPANY CODE OF ETHICS FOR SENIOR FINANCIAL OFFICERS Statement of Principle Our policy is to maintain the highest standard of moral and ethical behavior in our relationships with
More informationPITTSBURGH CARE PARTNERSHIP, INC. COMMUNITY LIFE PROGRAM POLICY AND PROCEDURE MANUAL. False Claims Act Explanation and Reporting Requirements
SUBJECT: False Claims Act Explanation and Reporting Requirements NUMBER: 1004 CROSS REFERENCE NUMBER: 1823 REG. REF.: 31 U.S.C. 37-29 PURPOSE: POLICY: The purposes of this policy are to describe the Federal
More informationStrategies to Evaluate the Effectiveness of Your Compliance Program. Compliance Program Check-up
Strategies to Evaluate the Effectiveness of Your Compliance Program Debbie Troklus, CHC-F, CCEP-F, CHRC, CHP Managing Director, Aegis Compliance & Ethics Center, LLP dtroklus@aegis-compliance.com 502-641-9140
More informationCCQC Compliance Training
CCQC Compliance Training Compliance Officers Community of Practice MTA, Inc 1 Provider Actions Develop your compliance program s action plan for this year using the OIG Workplan. Determine the effectiveness
More informationFebruary 2015. Audit committee performance evaluation
February 2015 Audit committee performance evaluation Audit committee performance evaluation The following questionnaire is based on emerging and leading practices to assist in the self-assessment of an
More informationThe University of British Columbia Board of Governors
The University of British Columbia Board of Governors Policy No.: 111 Approval Date: June 2008 Last Revision: [2013] Responsible Executive: President Title: Internal Audit, Investigations, and Financial
More informationWestlake Convalescent Hospital
Title: False Claims Act Policy Manual: Administrative Policy Manual Category: Business function Approval Signatures: Westlake Convalescent Hospital Document #: Original Issue: 02/01/2006 Revision Date:
More informationMEMORANDUM. Wayne A. McNulty Senior Assistant Vice President & Chief Corporate Compliance Officer. DATE: September 29, 2015 DEFICIT REDUCTION ACT
nyc.gov/hhc O F F I C E O F C O R P O R A T E C O M P L I A N C E * 160 Water Street, Suite 1129, New York, NY 10038 * Tel: (646) 458-7799 * e-mail: wayne.mcnulty@nychhc.org Wayne A. McNulty, Esq., CHC,
More informationSOUTH NASSAU COMMUNITIES HOSPITAL One Healthy Way, Oceanside, NY 11572
SOUTH NASSAU COMMUNITIES HOSPITAL One Healthy Way, Oceanside, NY 11572 POLICY TITLE: Compliance with Applicable Federal and State False Claims Acts POLICY NUMBER: OF-ADM-232 DEPARTMENT: Hospital-wide CROSS-REFERENCE:
More informationPrepared by: The Office of Corporate Compliance & HIPAA Administration
Gwinnett Health System s Annual Education 2014 Corporate Compliance: Our Commitment to Excellence Prepared by: The Office of Corporate Compliance & HIPAA Administration Objectives After completing this
More informationFraud, Waste and Abuse
Fraud, Waste and Abuse Policy Statement: Justification: Departments Involved: All LOBs Involved: All Colorado Access is dedicated to providing quality healthcare services to members while conducting business
More informationCOMPLIANCE PROGRAM GUIDANCE FOR MEDICARE FEE-FOR-SERVICE CONTRACTORS
Department of Health and Human Services CENTERS FOR MEDICARE & MEDICAID SERVICES COMPLIANCE PROGRAM GUIDANCE FOR MEDICARE FEE-FOR-SERVICE CONTRACTORS March 2005 TABLE OF CONTENTS INTRODUCTION...3 ELEMENTS
More informationCompliance with Applicable Federal and State Laws - False Claims Act and Similar Laws
Laws - False Claims Act and Similar Laws Purpose The purpose of this policy ( Policy ) is to provide information regarding: the federal and state False Claims Acts ( FCA ), related administrative remedies
More informationWhat is a Compliance Program?
Course Objectives Learn about the most important elements of the compliance program; Increase awareness and effectiveness of our compliance program; Learn about the important laws and what the government
More informationSUSPICIOUS ACTIVITY DETECTION AND BILLING INVESTIGATIONS
SUSPICIOUS ACTIVITY DETECTION AND BILLING INVESTIGATIONS New Mexico Medicaid False Claims Act OptumHealth has four core modules related to Recovery and Resiliency. These programs provide an overview of
More informationCPCA California Primary Care Association
CPCA California Primary Care Association Managing the Compliance Risk of Fraud, Abuse and the False Claims Act CPCA CFO Conference Larry Garcia Kenneth Julian April 30, 2010 Background The Patient Protection
More informationCORPORATE COMPLIANCE POLICY AND PROCEDURE
Title: Fraud Waste and Abuse Laws in Health Care Policy # 1011 Sponsor: Corporate Approved by: Carleen Dunne, Director, Corporate and Privacy Officer Issued: Page: 1 of 7 June 25, 2007 Last Reviewed/Updated
More informationC O N F I D E N T I A L A N D P R O P R I E T A R Y. Page 1 of 7 Title: FRAUD, WASTE, AND ABUSE POLICY
Page 1 of 7 1. Purpose As a Company that does business with U.S. state and federal government health care programs (such as Medicare and Medicaid), Hill-Rom is required to maintain a system of policies
More informationUMDNJ COMPLIANCE PLAN
UMDNJ COMPLIANCE PLAN INTRODUCTION...2 COMPLIANCE OVERSIGHT 3 COMPLIANCE COMMITTEE STRUCTURE...4 CHIEF COMPLIANCE OFFICER S RESPONSIBILITIES...5 RESEARCH COMPLIANCE.5 UNIT IMPLEMENTATION.6 COMPLIANCE POLICIES
More informationAlcohol, Drug and Mental Health Services (ADMHS) Compliance Plan Title 42 CFR, Section 438.608
Alcohol, Drug and Mental Health Services County of Santa Barbara Making a Difference Since 1969 300 North San Antonio Road, Bldg. 3 Santa Barbara, CA 93110 Telephone: 805.681.5220 Facsimile: 805.681.5262
More informationUpdate approved by the Board of Directors of Fiat S.p.A. May 2, 2014. 2014 Fiat Group Whistleblowing Procedure
Update approved by the Board of Directors May 2, 2014 2014 Fiat Group 2 Fiat Group Contents 1. Foreword... 3 2. Applicable external and in-house regulations... 3 3. Duties and responsibilities... 3 4.
More informationVILLAGECARE CORPORATE COMPLIANCE POLICY AND PROCEDURE MANUAL ORIGINAL EFFECTIVE DATE: JANUARY 1, 2007
VILLAGECARE CORPORATE COMPLIANCE POLICY AND PROCEDURE MANUAL SUBJECT: COMPLIANCE WITH FEDERAL AND STATE FALSE CLAIMS LAWS AND DETECTION AND PREVENTION OF FRAUD, WASTE AND ABUSE LAST POLICY REVISION EFFECTIVE
More informationBLESSING CORPORATE SERVICES QUINCY, ILLINOIS
BLESSING CORPORATE SERVICES QUINCY, ILLINOIS Policy No. BCSCGR.015 Policy Title: Section/Function: 2: Compliance & Government Regulations Administrative Responsibility: VP, Corporate Compliance & Organizational
More informationINDIANA UNIVERSITY SCHOOL OF OPTOMETRY HIPAA COMPLIANCE PLAN TABLE OF CONTENTS. I. Introduction 2. II. Definitions 3
INDIANA UNIVERSITY SCHOOL OF OPTOMETRY HIPAA COMPLIANCE PLAN TABLE OF CONTENTS I. Introduction 2 II. Definitions 3 III. Program Oversight and Responsibilities 4 A. Structure B. Compliance Committee C.
More informationFalse Claims Act NUMBER NH-LD-CP-220 Last Revised/Reviewed TITLE. Apr13. LD, CP Corporate Wide TJC FUNCTIONS APPLIES TO I.
ADMINISTRATIVE TITLE False Claims Act NUMBER NH-LD-CP-220 Last Revised/Reviewed Effective Date: TJC FUNCTIONS APPLIES TO LD, CP Corporate Wide Apr13 I. SCOPE / PURPOSE It is the policy of Novant Health
More information