Corporate Compliance & Ethics

Compliance at Broward Health

The compliance program helps make sure that Broward Health follows the rules set by the government. These rules are in place to prevent things like fraud, unfair payments or other illegal acts.

Below are some important rules that we must follow.

Acts, Rules and Statutes to Protect You

Anti-Kickback Statute (AKS)

It is illegal to give or receive gifts, money, or other rewards in exchange for business or for referring patients to a particular doctor or hospital. This is important to make sure that medical decisions are based on what is best for the patient, not because the provider will receive a gift or payment.

Beneficiary Inducement Statute (BIS)

No one should try to influence a patient’s choice of doctor or hospital by offering them a gift.

Civil Monetary Penalty Authority Related to HHS Grants, Contracts and Other Agreements (CMP)

Healthcare entities must be honest when it comes to government grants, contracts, or other agreements. If someone lies or hides information, they can be punished.

Exclusion Statute

Individuals or companies can be banned from receiving payments from federal health care programs if they have done something seriously wrong, such as submitting fraudulent claims.

False Claims Act (FCA)

This rule allows the government to take back money if someone tries to submit a claim for a payment they don’t deserve, such as when a doctor or hospital sends a bill for a service that wasn’t really provided. Providers must be careful to only send true and correct bills to the government.

The HIPAA Privacy Rule

The HIPAA Privacy Rule is a law that protects people’s medical records and personal health information. It gives patients rights over their health data and sets rules for doctors, hospitals and insurance companies on how they can use and share this information.

Information Blocking and the Cures Act

This rule requires doctors and hospitals to share patient information when they need to. It stops anyone from preventing the release of information if it is needed for the patient’s care.

Non-retaliation

No workforce member shall be disciplined or suffer any adverse employment action or other retaliation by Broward Health solely for making a compliance report in good faith where there has been a known or suspected compliance violation. However, discipline may be imposed if Broward Health reasonably determines that any complaint or report was knowingly fabricated or knowingly exaggerated, distorted or minimized so as to injure another or protect the reporting party or others who might be subject to discipline for a compliance violation.

Ga-004-305 Non-retaliation or Retribution Policy

Plans of Correction

If an audit or investigation reveals a material violation of Broward Health policies procedures and/or Medicare or Medicaid regulations and guidelines, the Internal Stakeholder will draft a plan of correction. The Internal Stakeholder will establish deadlines by which the plan of correction must be completed. Compliance staff will assist Internal Stakeholders throughout the plan of correction process. Examples include but are not limited to refunds of any overpayment received, employee disciplinary action up to and including termination, and reporting to federal or state authorities. All plans of correction will be documented, will include progress reports with respect to each error identified, will be maintained in the Corporate Compliance Department database, and may be reported to the ECG’s Auditing and Monitoring Subcommittee.

This is not an exhaustive list Corrective actions may include:

Policy/Procedure Revision
Training/Education
Disciplinary action

Progressive Action Policy

Stark (Physician Self-Referral) Law

Doctors may not send patients to receive care or treatment from a company they own or their family member owns, unless there is a good reason. This is to make sure that treatment decisions are made based only on what is best for the patient, not so a provider or their family member will benefit financially.

Four Ways to Report a Compliance Issue

Report the incident to your immediate supervisor or Regional Compliance Officer
Call the anonymous, 24/7 Corporate Compliance and Ethics Hotline at 1-888-511-1370
Email [email protected]
Submit an online report to Symplr Compliance & Safety

More Information About Compliance & Ethics

Policies, Procedures and Code of Conduct

Committed to maintaining the highest standards of patient care, safety, and operational excellence

Privacy

Understand your rights at Broward Health, including HIPAA and obtaining medical records.