Detected Offenses and Developing Corrective Action Initiatives
1. Prevention and Detection
Broward Health is committed to advancing the prevention of fraud, waste, and abuse while at the same time furthering the fundamental mission of providing enhanced patient care to our patients for the betterment of the community. One of the Compliance Department’s functions is reviewing and proposing strategies to promote compliance and detection of potential violations.
2. Investigations and Reporting
Reports or reasonable indications of fraud, waste or abuse, violations of Broward Health’s compliance program, violations of Broward Health’s Code of Conduct, or violations of applicable laws and regulations are promptly investigated. The purpose of the investigation shall be to identify those situations involving fraud, waste, abuse, relevant violations and unacceptable conduct; also, to identify individuals who may have knowingly or inadvertently caused or participated in such instances. The results of an investigation may identify the need for further training and education; to facilitate corrective action; and to implement procedures necessary to ensure future compliance.
Because of the many situations or problems which are possible, the process or method of investigation is at the discretion of the Compliance Officer and will be determined on a case-by-case basis, with consultation from the Office of General Counsel, and in coordination with the President/CEO of Broward Health as appropriate.
The Chief Compliance Officer will identify, summarize, and present to the Board of Commissioners any external investigations initiated and paid for by Broward Health. The Chief Compliance Officer will report on all investigations to the CEO, General Counsel, and the Chairman of the Board of Commissioners on a monthly basis.
When there is information of potential compliance violations or misconduct, the Chief Compliance Officer has the responsibility of conducting an investigation. An internal investigation may include interviews and a review of medical records, billing, and other relevant documents.
3. Plans of Correction
A plan of action will be obtained promptly following completion of an audit or investigation. If an audit or investigation reveals a material violation of Broward Health policies or 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 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 and include progress reports with respect to each error identified and 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
- Disciplinary action
Once an overpayment has been quantified, a prompt refund will be made to Federal Health Care Program (i.e. Medicare, Medicaid, etc.). Any required disclosures will be made by the Chief Compliance Officer, in collaboration with others as needed. In compliance with federal rules and regulations any identified overpayment will be paid back within 60 days.
If another department identifies other significant incorrect receipt of revenue, the Corporate Compliance Department will be notified and will receive a copy of the accounting documentation supporting the repayment. The Chief Compliance Officer will determine if further review is needed.