Policy Manual sample

MDT Home Health Care Agency, Inc. COMPLIANCE PROGRAM PURPOSE: To outline the compliance program elements and requirements. GENERAL STATEMENT: The Office of the Inspector General (OIG) has issued guidelines to agencies in the development of internal controls that promote adherence to applicable federal and state law and to program requirements of federal, state, and private health plans. The Compliance Program should articulate the agency’s commitment to ethical conduct, while ensuring that adequate systems are in place that prevent fraud, abuse, or waste and that promote quality patient care. POLICY: · The agency’s Compliance Program contains the following elements: Written standards of conduct, as well as written policies and procedures that address specific areas of potential fraud The designation of a Compliance Officer and other appropriate bodies with responsibility for operating and monitoring the compliance program Regular education and training programs for affected staff A process to receive complaints and to protect the anonymity of complainants and to protect whistle blowers from retaliation A system to respond to allegations of improper/illegal activities and to enforce disciplinary actions against employees who have violated internal compliance The use of audits and other techniques to monitor compliance The investigation and correction of system problems and development of policies relating to retention of sanctioned individuals · Internal control mechanisms are in place to preclude the following prohibited activities from occurring: Billing for items or services not rendered Billing for medically unnecessary services Duplicate billing Filing of false cost report Failure to refund credit balances Provision of incentives to referral sources Joint ventures between parties to incite referral Physician self-referral law violations Billing for non-homebound patient services Billing for visits to patients who do not require a qualifying service Over/under-utilization Billing for inadequate or substandard care Billing with insufficient documentation that services were performed Billing for home health coordination activities that are not allowable Billing for services provided by unlicensed or unqualified staff Home Health Agency Policies A-135