Corporate Compliance
Policy
The Board of Directors of Newborn Nurses/NBN Infusions corporate compliance plan to ensure that the agency acts in accordance with all applicable state and federal laws, and the program requirements of federal, state, and private health plans to ensure the submission of accurate claims. The agency will exercise due diligence in seeking to prevent and detect fraudulent conduct by its employees and other agents. The company must not convey, sell or reassign a supplier number. The company will not allow another entity to use its Medicare or other billing numbers.
Requirements
The compliance plan shall be implemented by the Compliance Officer, The Compliance Officer is appointed by the President, and retains that office until replaced by the appointment of a new officer. The Compliance Officer is charged with the responsibility of operating the compliance program. The Compliance Officer will not be the chief financial officer or any in-house counsel. The company must furnish CMS with any information required by Medicare statute and implementing regulations.
Procedures
The Compliance Officer's responsibilities will include:
- Continued development of the written compliance program.
- Establishment of a compliance agenda in the Risk Management committee and holding discussions at least annually and as needed.
- Overseeing the compliance programs operation.
- Establishing the employee communication system and training programs. These programs will be held initially and as needed thereafter.
- Responding to Hotline complaints.
- Ensuring an authorized signature from the President and/or COO (both of whose signatures are binding), signed the application for billing privileges with Medicare and other payers.
- Reviewing contracts with input as needed from legal counsel for kickback concerns.
- Ensuring contractors are aware of the agency requirements in the corporate compliance program.
- Ensure enforcement via disciplinary action sanction occurs.
- Ensure audits are performed of all pertinent operations.
- Disseminate information and regulatory updates.
- Report on an annual basis and as needed to the agency's Advisory Board, President and Risk Management Committee.
- Perform an initial and regular review of Medicare/Medicaid and insurance regulations; HCFA policy statements; and implement them.
- Implement as an element in the performance appraisal of supervisors and managers their promotion and adherence to the compliance program.
- Ensure that the agency does not contract or employ a sanctioned individual in accordance with the law.
- Ensure that a thorough investigation and remediation of any identified operational or personnel problems are performed.