Compliance Program and Exclusion Screening
Sets up the Agency's compliance program: a person responsible for compliance, written standards, training, a way to raise concerns without retaliation, auditing, and a prompt response to problems. It requires screening of every staff member and contractor against federal and Georgia exclusion lists before hire and monthly, and explains the false claims and anti-kickback rules that apply when the Agency bills Medicaid.
About this policy
- Policy number
- GA-HC-ETH-03
- Version
- 1.0
- Main rule
- O.C.G.A. §49-4-168 et seq.
- Library
- Georgia home care · 49 policies
- Category
- Ethics
- Sections
- 16
In short
- Bill and record only what really happened. A false visit record can be fraud under Georgia and federal law.
- Everyone is checked against exclusion lists before hire and every month. Tell the Administrator if you are excluded.
- Never give or accept money or gifts for client referrals.
- Report any concern about billing, records or fraud to your supervisor or the Administrator. You can do it anonymously.
- You are protected by law from retaliation for reporting in good faith.
What's inside
16 sections. The full text comes with the One-time Policy Pack.
- Terms of Reference
- 1. Purpose
- 2. Scope
- 3. Definitions
- 4. Policy Statement (O.C.G.A. §49-4-168 et seq.)
- 5. Elements of the Compliance Program
- 6. Exclusion Screening
- 7. False Claims and Kickbacks
- 8. Responding to a Problem
- 9. Responsibilities
- 10. Records and Compliance Monitoring
- 11. Staff Training
- 12. References
- 13. Related Policies and Forms
- 14. Approval
- 15. Revision History
An inspector may ask
- Who is responsible for compliance at your agency, and how do staff report a concern?
- Show me your exclusion screening for this employee at hire and for the last three months.
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