Compliance Program, Referral Practices, and Fraud Prevention
Establishes the Agency's compliance program: a compliance officer, written standards, training, a way to report concerns without retaliation, monthly exclusion screening, auditing, and corrective action; and prohibits the referral payments, gifts to beneficiaries, free staffing, patient brokering, kickbacks and false records and billing that Florida and federal law forbid.
About this policy
- Policy number
- FL-HC-ETH-02
- Version
- 1.0
- Main rule
- s. 400.474(6), F.S.
- Library
- Florida home care · 50 policies
- Category
- Ethics
- Sections
- 21
In short
- We never pay or give gifts to doctors, discharge planners or facility staff for referrals.
- We never give cash or gift cards to Medicare or Medicaid clients.
- Record only what you actually did and saw. Never chart ahead or sign for someone else.
- Report any concern about fraud or kickbacks to Pat Sample or the governing body. You can report anonymously, and you are protected from retaliation.
- We check every staff member against federal and Florida exclusion lists every month.
What's inside
21 sections. The full text comes with the One-time Policy Pack.
- Terms of Reference
- 1. Purpose
- 2. Scope
- 3. Definitions
- 4. Policy Statement (s. 400.474(6), F.S.)
- 5. Elements of the Compliance Program
- 6. Prohibited Referral Practices
- 7. Medical Director
- 8. Accurate Records and Billing
- 9. Exclusion Screening
- 10. Auditing and Monitoring
- 11. Reporting and Investigation
- 12. Correcting Problems
- 13. Consequences for the License
- 14. Responsibilities
- 15. Records and Compliance Monitoring
- 16. Staff Training
- 17. References
- 18. Related Policies and Forms
- 19. Approval
- 20. Revision History
An inspector may ask
- Who is your compliance officer, and how do staff report a concern?
- How often do you check staff against exclusion lists, and which lists?
See Cura Core with your agency's name on it.
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