Corporate Compliance
POLICY: It is the policy of Triangle Aftercare to establish and implement commencing in 2003 compliance standards and procedures to be followed by employees and other agents.1. The General Manager is responsible for global oversight of the Company’s corporate compliance, and to ensure at a minimum that the Company follows its written policies and procedures that address the company’s commitment to compliance. Those policies include, but are not limited to:
- Company Mission Statement
- Atmosphere of Excellence - Values and Standards Policy
- Administrative Structure and Staffing of MarLab, Inc. d.b.a. Triangle Aftercare Development and Revision of Policies and Procedures
- Development of Position Descriptions
- Personal Recruitment and Interview Policy
- OIG Risk Areas
- Orientation Program Policy
- Employee Competency
- In-Service/Continuing Education Policy
- Supervision of Employees
- Employee Performance Review
- Personnel and Contracted Service Involvement
- Contracted Services
- Contractual/Financial Arrangements
- Code of Ethics
- Scope of Service Education
- Progressive Discipline Policy
- Grievance Policy
- Scope of Services
- Client Referrals
- Anti-Discrimination Compliance
- Eligibility Assessment and Guidelines
- Strict Adherence to a Comprehensive Client Intake Procedure including the acceptance of patients only as they conform with the Company’s ability to provide appropriate, high quality service
- Physician Credentials Verification
- Client Bill of Rights and Responsibilities, Warranties and Returns
- Client Record
- Client Record Management
- Privacy Policy and Confidentiality of Patient Information
- Protection of Patient Confidentiality
- Client Safety and Protection Safeguards
- Identification, Prevention and Control of Infection
- Identification, Prevention and Control of Safety Hazards related to services
- Conflict of Interest
- Reimbursement Disclosure Policy
- Sound Fiscal Polices and Practices
- Accounting Activities
2. The Company will exercise care to avoid delegating substantial discretionary authority to individuals whom the organization knows, or should have known, have a propensity to engage in illegal activities.
3. The Director of Business Operations will assume the role of Corporate Compliance Officer. The function will be managed with strict anonymity, including acceptance by the Corporate Compliance Officer of information on a typed, unsigned document. He will report to the General Manager on a quarterly basis on ethical issues and his Corporate Compliance internal audit, starting Q3, 2005.
4. The company will effectively communicate standards and procedures to all employees and agents through its employee orientation and ongoing training and through regular Quality Improvement assessment.
5. The General Manager will ensure effective communication lines between management and employees.
6. The General Manager as a component of the Quality Improvement plan, will at least quarterly audit client and financial records and report results to the staff. Any improprieties that may affect accreditation, regulatory compliance or licensure will be reported to the appropriate accrediting body, regulatory or licensing agency.
7. The General Manager will ensure that the Company adheres to its stated policy of complying with all local, state and federal laws and regulations.
8. The General Manager will ensure that the Company’s disciplinary policy is implemented should any behaviors warrant such implementation.
9. The General Manager will ensure that a charge of fraud and abuse is thoroughly investigated. Under most circumstances, sixty (60) days will be sufficient to complete investigations.
- A description of how the alleged fraud and abuse was identified and the origin of the information that led to the disclosure.
- A detailed description and chronology of the investigative steps taken including:
- A list of all individuals interviewed, the dates of those interviews, the subject matter of each interview, business and home addresses and telephone numbers of each witness interviewed, and the positions and titles in the organization both currently and during the relevant time period.
- A description of the files, documents and records reviewed.
- A summary of auditing activity undertaken and a summary of the documents relied upon in support of cost impact determinations, if any.
