Compliance Program, Referral Integrity and Fraud Prevention
Sets the Agency’s compliance program: rules on referrals, gifts and marketing so that no one is paid or rewarded for referring patients, hospice eligibility integrity, the federal and District false claims laws and whistleblower protections, how staff report concerns without retaliation, and how the Agency investigates problems and reports and returns overpayments within 60 days of identifying them.
About this policy
- Policy number
- DC-HSP-ETH-01
- Version
- 1.0
- Main rule
- 42 U.S.C. §1320a-7b(b)
- Library
- Washington, DC hospice · 60 policies
- Category
- Ethics
- Sections
- 18
In short
- Never offer or accept anything of value in exchange for patient referrals.
- Admit only patients who are eligible, and document care truthfully and on time.
- Never sign for someone else or change a record after the fact.
- Report any compliance concern to the compliance officer. You can report anonymously.
- No one is punished for a good-faith report.
What's inside
18 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. §1320a-7b(b))
- 5. Rules for Staff
- 6. Referral Relationships and Physician Arrangements
- 7. Compliance Program
- 8. False Claims Laws and Whistleblower Protection
- 9. Reporting Concerns
- 10. Investigation, Overpayments and Corrective Action
- 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 your compliance officer? Show me your compliance work plan and the last audit results.
- How do you make sure your arrangements with physicians and nursing facilities comply with the Anti-Kickback Statute?
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