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Compliance Program, Fraud Prevention, and Exclusion Screening

Sets up the Agency's compliance program: a person responsible for compliance, written standards, training, a safe way to raise concerns, auditing, and prompt correction. Requires screening of every employee and contractor against the federal and NC Medicaid exclusion lists before hire and every month, explains the North Carolina and federal false claims and anti-kickback laws, and bans gifts or inducements to beneficiaries.

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About this policy
Policy number
NC-HC-ETH-03
Version
1.0
Main rule
10A NCAC 13J .0906(a)
Library
North Carolina home care · 50 policies
Category
Ethics
Sections
17

In short

  • Bill and record honestly. A false claim to Medicaid is against the law.
  • The Agency checks every employee against federal and state exclusion lists before hire and every month.
  • Never pay or accept anything for a client referral, and never give clients gifts to choose the Agency.
  • Report any concern about fraud to a supervisor or the Agency Director. You can report anonymously.
  • You will not be punished for reporting a concern in good faith.

What's inside

17 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 (10A NCAC 13J .0906(a))
  • 5. Elements of the Compliance Program
  • 6. Exclusion Screening
  • 7. Gifts and Inducements to Beneficiaries
  • 8. False Claims and Kickbacks
  • 9. Responding to a Problem
  • 10. Responsibilities
  • 11. Records and Compliance Monitoring
  • 12. Staff Training
  • 13. References
  • 14. Related Policies and Forms
  • 15. Approval
  • 16. Revision History

An inspector may ask

  • Who is responsible for compliance here, and how does a staff member report a concern?
  • Show me your exclusion screening for this employee at hire and for the last three months.

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