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Compliance Program, Referral Integrity, Marketing and Fraud Prevention

Sets out the Agency's compliance program and the rules of conduct that keep hospice referrals, marketing, billing and relationships with patients honest: no kickbacks or referral payments, the Michigan Medicaid hospice marketing limits, no false claims, no pressure to elect hospice, no gifts or financial dealings with patients, how to report concerns, and protection from retaliation.

Preview: full text with a package
About this policy
Policy number
MI-HSP-ETH-01
Version
1.0
Main rule
MCL 400.604
Library
Michigan hospice · 59 policies
Category
Ethics
Sections
19

In short

  • Never offer patients or families cash, gifts or free extras to choose or stay with the Agency.
  • Never claim the Agency gives better care than other hospices. Say only what is true.
  • Do not accept money, gifts, loans or a place in a will from a patient or family.
  • Never pay or accept anything for a referral.
  • Report any concern to the compliance officer. You will not be punished for reporting in good faith.

What's inside

19 sections. The full text comes with the One-time Policy Pack.

Full text with a package
  • Terms of Reference
  • 1. Purpose
  • 2. Scope
  • 3. Definitions
  • 4. Policy Statement (MCL 400.604; Michigan Medicaid Provider Manual, Hospice, Section 2)
  • 5. Dealings With Patients and Families
  • 6. Advertising and Marketing
  • 7. Relationships With Referral Sources
  • 8. Fraud and Abuse Laws
  • 9. The Compliance Program
  • 10. Reporting Concerns
  • 11. No Retaliation
  • 12. Responsibilities
  • 13. Records and Compliance Monitoring
  • 14. Staff Training
  • 15. References
  • 16. Related Policies and Forms
  • 17. Approval
  • 18. Revision History

An inspector may ask

  • How do you make sure staff do not offer patients gifts to choose your hospice?
  • Who is your compliance officer, and how do staff report a concern?

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