Policy Manual sample

MDT Home Health Care Agency, Inc. False dating of amendments to nursing clinical notes Falsified Plan of Care Untimely or forged physician plan of care certification Forged beneficiary signatures on visit notes of logs to verify services were performed Improper patient solicitation or marketing Inadequate oversight of subcontracted services, leading to improper billing Discriminatory admission and discharge of patients Billing for unallowable costs related to agency purchase or sale Compensation programs giving incentives based on visits and revenue generated improper influence over referrals by a hospital owing a home health agency Patient abandonment Misuse of provider certification numbers, leading to improper billing Duplication of services provided by assisted living facilities, hospitals, clinics, physicians, or other home health agencies Providing service when an able and willing caregiver is available Failure to adhere to licensure requirements and Medicare Conditions of Participation Failure to return federal program overpayments PROCEDURE: · The agency Administrator assumes overall responsibility for the program and is appointed as the Agency’s Compliance Officer. · The Compliance Officer may establish a committee of staff and Board as appropriate to assist in education/decision making. All information is confidential · The Compliance Officer reports on the Compliance Program to the appropriate Board committee and/or full board. The function of the Compliance Committee and Compliance Officer is to make all necessary effort and initiative to assure that our Agency is fully compliant with all State and Federal regulations, which may include, but not limited to: Ant-Fraud Policy, Anti Kick Back Policy, Compliance with all Medicare, Medicaid Regulations, Compliance with all HIPAA Privacy Rules, etc. Compliance Officer: Administrator: _____________________________________________ Compliance Committee Members: ___________________________________________________ ______________________________________________________________________________ ______________________________________________________________________________ Home Health Agency Policies A-136