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Compliance Program, Exclusion Screening, and Fraud Prevention

Sets up the Agency’s compliance program on the seven elements in the federal Office of Inspector General’s guidance: written standards, a compliance lead, training, ways to report concerns without fear of retaliation, consistent discipline, auditing and monitoring including monthly exclusion screening, and prompt response and correction, with reports to the governing body.

Preview: full text with a package
About this policy
Policy number
OH-HH-ETH-01
Version
1.0
Main rule
42 CFR §1001.1901
Library
Ohio home health · 59 policies
Category
Ethics
Sections
17

In short

  • If you see something that may be wrong, such as false notes, billing errors or kickbacks, report it to your supervisor or the Administrator.
  • You can report anonymously on the Compliance Concern Report.
  • The Agency will not punish you for reporting in good faith.
  • Everyone is checked monthly against the federal and Ohio exclusion lists.
  • Compliance training is at orientation and every year.

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 (42 CFR §1001.1901)
  • 5. The Seven Elements
  • 6. Exclusion Screening
  • 7. Reporting a Concern
  • 8. Investigation and Correction
  • 9. Employee Education About False Claims
  • 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 runs your compliance program, and how does staff report a concern?
  • Show me your exclusion screening for all staff and contractors last month.

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