OUTLINE FOR AGENCY CORPORATE COMPLIANCE PLAN



I. Introduction

o Provide an overview of your agency:

a) Mission, Vision and Values

b) Clearly define the clients the agency serves

c) Briefly describe agency’s commitment to service excellence and commitment to assuring the highest ethical and legal behavior throughout the organization.

II. Goals and Objectives

o List your agency’s goals and objectives. May include…

a) Compliance with all applicable federal, state, and local laws and regulatory requirements.

b) Compliance with all applicable accreditation and licensure standards.

c) provide services in an ethical manner with an expectation of excellence and quality in service delivery

d) Ensure sufficient, accurate and complete documentation is maintained in all client records.

e) Ensure the security and confidentiality of client records.

f) Ensure honest and ethical billings and financial practices

III. Code of Ethics

o A clear description of what the agency’s code of ethics is and the expectation of employees (may reference other discipline and professional licensing ethical standards).

IV. Billing Standards

o The False Claims Act is a federal law that prohibits an individual or organization who receives money from the federal government from submitting a request for payment knowing that such a request contains false information. An organization or individual may be held liable under the False Claims Act if it knew, should have known, or disregarded information indicating that a claim submitted to the federal government for payment of health care services contained false information

Responsibility

o This section should identify who the Agency’s Chief Compliance Officer is and what his/her responsibilities our. This section should also describe the Governing Board and Chief Executive Officer responsibilities related to corporate compliance. Finally this section should describe any committees and the functions they perform related to compliance task.

V. Regulations, Policy and Procedures:

o This section should list by title all Federal and state regulating bodies that the Agency must comply with in regards to corporate compliance and ethical practice. This section should also list any related internal policies or procedures employees need to be aware of.

VI. Auditing and Monitoring Functions

o This section should describe all the various internal and external audits and monitoring reviews that take place in the agency on an ongoing basis. There should be at least one option for staff to report while remaining anonymous.

VII. Avenues to Report Suspected Corporate Compliance Violations

o This section should describe how employees and other agency stakeholders should report suspected violations (written, oral etc) and what the penalties are for failing to report.

VIII. Protection from Retaliation

o This section should describe the “whistle blower” protection clause contain in the false claims act.

o The False Claims Act provides protection for employees who report suspected false claims. Employees who are terminated, demoted, suspended, or otherwise mistreated for reporting suspected false claims are entitled, under the False Claims Act, to reinstatement of their earlier position, back pay, and compensation for any other special damages which result from retaliation.

IX. Responding to Reports and Developing Corrective Action

o The purpose of this section is to set forth the procedures that will be used by the agency to respond to reports by employees or others concerning activity that may be non-compliant. Suspected violations will be reviewed as promptly and as discreetly as possible under the circumstances of each event.

o This section should describe the process the agency will take to investigate allegations of wrong doing. Should identify what reporting obligations are to external regulating bodies and should describe what action(s) the agency’s is going to take to make sure the wrong doing does not occur again (i.e. re-train staff, take corrective discipline)

X. Training and Education

o This section should describe how the agency will ensure that all employees understand their responsibilities related to corporate compliance. (May include employee sign a document that they have been provided a copy of the agency’s plan been trained and agreed to abide).

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