Policy Manual

Federal

Policy Manual Compliance

Not compliant

Overall Federal Compliance

Federal Requirements

Assigned Roles and Completed Tasks (OIG Compliance)

One employee has been designated as the compliance officer, is trained, is identified in the Compliance Manual.

Read more: OIG Compliance: Getting Started, Creating A Culture of Compliance

Antitrust

Written policy established [1] that strictly prohibits discussions or agreements regarding prices with any outside providers.

Stark and Anti-Kickback Laws

Ensure that business relationships with third-party vendors and contractors comply with applicable laws and regulations, including anti-kickback and Stark laws.

Read more: Avoiding Medicare and Medicaid Fraud

Written policy established [1] that prohibits the exchange of anything of value in return for referrals or purchases of healthcare services paid for by federal healthcare programs (anti-kickback statute).

Read more: Self Referral and Anti Kickback Laws

All contracts and arrangements have been reviewed to ensure that all parties are being compensated at fair market value.

Read more: Self Referral and Anti Kickback Laws

Written policies (OIG Compliance)

Implement written policies [1], procedures, and standards of conduct that address high-risk areas for fraud and abuse.

Read more: Creating A Culture of Compliance

Provide regular training and education to all employees, including physicians, on the compliance program, laws and regulations, open communication lines, and ethical standards.