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Compliance Program, Conflicts of Interest, and Fraud Prevention

Sets up the Agency's compliance program: who leads it, how staff raise concerns, accurate records and billing, conflicts of interest, exclusion screening, audits, and how problems are investigated, corrected and reported.

Preview: full text with a package
About this policy
Policy number
DC-HC-ETH-02
Version
1.0
Main rule
22-B DCMR §9900.3
Library
Washington, DC home care · 50 policies
Category
Ethics
Sections
18

In short

  • Record only what you actually did, when you did it. Never record a visit or a task that did not happen.
  • Never steer a client to a business you or your family have an interest in. Give clients a choice.
  • If you suspect fraud or any breach of the rules, tell your supervisor, the Director or the governing body. You may report anonymously.
  • You will not be punished for reporting a concern in good faith.
  • Tell the Director if you are related to a client or have a business that serves our clients.

What's inside

18 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 (22-B DCMR §9900.3)
  • 5. Elements of the Compliance Program
  • 6. Accurate Records and Billing
  • 7. Annual Compliance Audit
  • 8. Conflicts of Interest
  • 9. Exclusion Screening
  • 10. Reporting and Investigating Concerns
  • 11. Responsibilities
  • 12. Records and Compliance Monitoring
  • 13. Staff Training
  • 14. References
  • 15. Related Policies and Forms
  • 16. Approval
  • 17. Revision History

An inspector may ask

  • Who is responsible for compliance at your Agency, and how does staff report a concern?
  • How do you make sure you bill only for services actually provided?

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