| Yes | No | N/A | ||
|---|---|---|---|---|
| 1 | Available written standards of conduct that promote commitment to compliance | |||
| 2 | Have these standards of conduct been distributed to all personnel | |||
| 3 | Are there policies regarding OIG compliance requirements | |||
| 4 | Are the policies been followed and updated annually | |||
| 5 | Is a staff member designated as a compliance officer | |||
| 6 | Is there a job description for the compliance officer | |||
| 7 | Are there any metrics to ensure actions or measure compliance officer's performance | |||
| 8 | Are there any processes to receive complaints and protect anonymity of complainant | |||
| 9 | Is there an education and training programs for all appropriate employees | |||
| 10 | Are there copies of the lesson plans used | |||
| 11 | Are the lessons plans updated annually | |||
| 12 | Are there internal systems to respond to allegations of improper/illegal activities | |||
| 13 | Does the system and policies incorporate enforcement of disciplinary actions to violators | |||
| 14 | Has there been any compliance activity in the last six months | |||
| 15 | Are medical records and bills audited for compliance | |||
| 16 | Is there a third party conducting audits in behalf of the organization | |||
| 17 | Are there any results of the audits available | |||
| 18 | Are there established mechanisms to investigate and correct identified systematic problems | |||
| 19 | Are there policies addressing the employment of sanctioned individuals | |||
| 20 | Does the workforce clearance policy include verification with the OIG web site | |||
| 21 | Have the organization identified risk factors (coding/billing, improper inducements) | |||
| 22 | Does the organization tracks billing problems (mistakes, rejections, denials) | |||
| 23 | Identify 4 action items of present policy and ensure they are been accomplished? | |||
| a | ||||
| b | ||||
| c |