Compliance Plan

1. A Compliance Officer has been appointed to make sure that Newborn Nurses/NBN Infusions/New Behavioral Network is running in compliance with the spirit and letter of statutes and regulations governing our industry. He/she will oversee compliance standards and procedures.
2. All prospective billing personnel shall have a criminal background check conducted.
3. Hotline established to report criminal conduct or suspected criminal conduct.
4. If after hiring an employee it is found to have been convicted of a crime or misdemeanor, or if he/she lied about criminal activity, the result of the criminal check will be sent to the attorney for review, and disposition. All employees who have a positive criminal history will be terminated.
5. All parents will be notified about reporting any impropriety via the hotline. Hotline reports are handled in a confidential manner. Reports may be made anonymously, and without concern over retribution and/or job loss.
6. All compliance procedures will be reviewed with the billing department. There will be documentation on file of each service provided for all services billed. The appropriate insurance carrier will be billed for services.
7. All employees will be notified about reporting any impropriety via the hotline.
8. Nursing supervisors will submit signed time slips with their logs to verify their time at the patient's home. All visit nurses will submit signed time slips with their notes. Independent contractors will submit a signed time slip or document with their bills.
9. Periodic unscheduled visits will be made for acute care visit staff and nursing supervisors as well as the chronic care staff.
10. Annual financial audits will be conducted by our independent accounting firm.
11. All complaints made by clients regarding employees impropriety, will be reviewed by the compliance officer. If fraud is suspected, the employee will be notified. In conjunction with our attorneys, disposition will be made regarding termination or probation.
12. Acute care and chronic care supervisors will be trained to ensure that POT's and verbal orders are obtained and signed to match the service provided. Additional training and supervision through patient rounds will be done to insure that services are medically necessary and to the intensity pattern provided.
13. All advertising of agency services will be reviewed for accuracy to ensure no misrepresentation to the public is made.
14. Intake staff will be trained to provide patients and case managers with accurate Information related to potential payment liability. Documentation of the provision of this information will be done in the telephone log.