{"ref":"MI-HC-ETH-03","title":"Compliance Program, Fraud Prevention, and Exclusion Screening","category":"Ethics","summary":"Sets up the Agency's compliance program: a compliance lead, written standards, training, an open reporting line with protection from retaliation, exclusion and sanction screening before hire and every month, accurate billing and documentation, prompt return of overpayments, and cooperation with the MDHHS Office of Inspector General and the Attorney General's Health Care Fraud Division.","inShort":["Bill and document only care you actually gave, on the day and time you gave it.","The Agency checks every worker against exclusion lists before hire and every month.","Report suspected fraud to your supervisor or the Administrator, or to 1-855-MI-FRAUD (1-855-643-7283), www.michigan.gov/fraud.","Michigan law protects workers who report fraud from retaliation.","If the Agency was paid too much, it pays the money back promptly."],"primaryCitation":"MCL 400.601 et seq.","citations":["MCL 400.601 et seq.","MCL 400.610c","MCL 400.111b(16)","MCL 400.111b(17)","MPM General Information for Providers §1.8","MPM General Information for Providers §7.1","MPM General Information for Providers §11.4","MPM General Information for Providers §15","MPM MI Choice Waiver §9.4","MPM Home Help §8.8","MPM Home Help §8.11.B"],"federalCitations":["42 U.S.C. §1320a-7","42 U.S.C. §1320a-7k(d)","31 U.S.C. §3729 et seq.","42 U.S.C. §1396a(a)(68)"],"surveyorAsks":["How often do you check staff against the federal exclusion list and the MDHHS sanctioned provider list? Show me last month's check.","What would you do if you found you had billed for a visit that did not happen?"],"forms":[{"ref":"MI-HC-ETH-03-A","title":"Exclusion and Sanction Screening Log"}],"headings":["Terms of Reference","1. Purpose","2. Scope","3. Definitions","4. Policy Statement (MCL 400.601 et seq.)","5. Compliance Program Elements","6. Exclusion and Sanction Screening","7. Accurate Billing and Documentation","8. Overpayments","9. Reporting Suspected Fraud and Protection from Retaliation","10. Responsibilities","11. Records and Compliance Monitoring","12. Staff Training","13. References","14. Related Policies and Forms","15. Approval","16. Revision History"],"version":"1.0","sample":false,"pack":"mi-hca","state":"Michigan","service":"Home care","guides":[{"path":"/guides/home-care-agency-policies/","h1":"What policies does a home care agency need?"}],"agency":{"name":"Sample Agency","legalName":"Sample Agency, LLC","logo":null}}