Compliance Program, Exclusion Screening, and Fraud Prevention
Sets up the Agency’s compliance program, built on the HHS-OIG elements, with a code of conduct, a way to report concerns without retaliation, screening of every employee and contractor against the Pennsylvania Medicheck List and the federal exclusion list at hire and every month, auditing, investigation and correction, and information on the False Claims Act.
About this policy
- Policy number
- PA-HH-ETH-02
- Version
- 1.0
- Main rule
- 62 P.S. §1407
- Library
- Pennsylvania home health · 56 policies
- Category
- Ethics
- Sections
- 20
In short
- Follow the code of conduct and sign it every year.
- Report any concern about fraud, false records or wrong bills; you will not be punished for a good-faith report.
- We check every employee and contractor against the Pennsylvania Medicheck List and the federal exclusion list when hired and every month.
- Tell the Administrator at once if you are excluded from any health care program or your license is disciplined.
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 (62 P.S. §1407)
- 5. Compliance Officer and Oversight
- 6. Code of Conduct
- 7. Reporting Concerns and Non-Retaliation
- 8. Exclusion Screening
- 9. If a Match Is Confirmed
- 10. Auditing and Monitoring
- 11. Investigation, Correction, and Discipline
- 12. 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 runs your compliance program? Show me your code of conduct and signed acknowledgments.
- Show me your exclusion screening for this month. Which lists do you check?
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