Compliance Program, Referral Integrity and Fraud Prevention
Sets the Agency’s compliance program: a compliance officer, written standards, training, a way to report concerns without retaliation, monitoring of hospice risk areas (eligibility, length of stay, levels of care, live discharges, marketing), and the rules against kickbacks, patient brokering, false claims, inducements to patients and conflicts of interest, with prompt return of overpayments.
About this policy
- Policy number
- FL-HSP-ETH-01
- Version
- 1.0
- Main rule
- 42 U.S.C. §1320a-7b(b)
- Library
- Florida hospice · 60 policies
- Category
- Ethics
- Sections
- 18
In short
- Never offer, pay or accept anything of value for referring patients.
- Document and bill only care you actually gave. Never change dates or records.
- Do not accept money, gifts beyond a small token, loans or anything in a patient’s will.
- Report any compliance concern to your supervisor or the compliance officer. You may report without giving your name.
- You will not be punished for a good-faith report.
What's inside
18 sections. The full text comes with the One-time Policy Pack.
- Terms of Reference
- 1. Purpose
- 2. Scope
- 3. Definitions
- 4. Policy Statement (s. 817.505, F.S.; s. 456.054, F.S.; 42 U.S.C. §1320a-7b(b))
- 5. Elements of the Compliance Program
- 6. Referral Relationships, Gifts and Conflicts
- 7. Hospice Risk Areas and the Audit Plan
- 8. Reporting and Investigating Concerns
- 9. Overpayments
- 10. False Claims
- 11. Responsibilities
- 12. Records and Compliance Monitoring
- 13. Staff Training
- 14. References
- 15. Related Policies and Forms
- 16. Approval
- 17. Revision History
An inspector may ask
- Who is your compliance officer, and how do staff report a concern?
- Show me your annual compliance training and the signed attestations.
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