A.
Written Policies and Procedures
1. Standards of Conduct
2. Risk Areas
3. Claim Development and Submission Process
a. Outpatient services rendered in connection with an inpatient
stay
b. Submission of Claims for laboratory services
c. Physicians at teaching hospitals
d. Cost Reports
4. Medical Necessity - Reasonable and Necessary Services
5. Anti-kickback and Self-Referral Concerns
6. Bad Debts
7. Credit Balances
8. Retention of Records
9. Compliance as an Element of a Performance Plan
B.
Designation of a Compliance Officer and a Compliance
Committee
1. Compliance Officer
2. Compliance Committee
C.
Conducting Effective Training and Education
D.
Developing Effective Lines of Communication
1. Access to the Compliance Officer
2. Hotlines and Other Forms of Communication
E.
Enforcing Standards Through Well-Publicized Disciplinary
Guidelines
1. Discipline Policy and Actions
2. New Employee Policy
F.
Auditing
and Monitoring
G. Responding
To Detected Offenses And Developing Corrective Action Initiatives
1. Violations and Investigations
2. Reporting
