Compliance Program, Exclusion Screening, and False Claims Prevention
Sets up the Agency's compliance program: oversight by the Administrator and governing body, a code of conduct, safe ways to report concerns without retaliation, monthly exclusion screening of staff and contractors, auditing, investigation and repayment, and the written information on the federal and Missouri false claims laws and whistleblower protections that Section 6032 of the Deficit Reduction Act requires and MMAC's annual attestation confirms.
About this policy
- Policy number
- MO-HH-ETH-01
- Version
- 1.0
- Main rule
- 42 U.S.C. §1396a(a)(68)
- Library
- Missouri home health · 57 policies
- Category
- Ethics
- Sections
- 20
In short
- Bill only for care that was ordered, given and documented. Never falsify a record or EVV entry.
- Report any concern about fraud, waste or abuse to your supervisor or the Administrator. You can report anonymously.
- No one may be punished for reporting in good faith; Missouri and federal law protect whistleblowers.
- Everyone who works with us is checked every month against federal exclusion lists.
- False claims can lead to large penalties under federal and Missouri law.
What's inside
20 sections. The full text comes with the One-time Policy Pack.
- Terms of Reference
- 1. Purpose
- 2. Scope
- 3. Definitions
- 4. Policy Statement (42 U.S.C. §1396a(a)(68))
- 5. Compliance Oversight
- 6. Code of Conduct
- 7. Reporting Concerns and Non-Retaliation
- 8. Exclusion Screening
- 9. If a Match Is Found
- 10. Auditing and Monitoring
- 11. Investigation, Correction, and Discipline
- 12. The False Claims Laws
- 13. Responsibilities
- 14. Records and Compliance Monitoring
- 15. Staff Training
- 16. References
- 17. Related Policies and Forms
- 18. Approval
- 19. Revision History
An inspector may ask
- Who is responsible for compliance, and how does the governing body address findings of fraud or waste?
- How often do you check staff and contractors against the exclusion lists? Show me last month's results.
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