I. Introduction
Godwin Corporation is committed to conducting its business with integrity, honesty, and fairness, and in accordance with all applicable laws regarding reimbursement for healthcare related claims. Godwin is particularly committed to ensuring that our claims represent rendered services and reflect the time worked by our employees and non-employees that independently contract with our corporation. To ensure compliance with these laws, Godwin has adopted this compliance plan. This plan is based largely on the guidance for hospitals provided by the Office of Inspector General (“OIG”) in its effort to assist healthcare entities in developing voluntary compliance programs.
II. Code of Conduct
A. Mission Statement
- To provide the highest possible quality services in our field.
- To do everything possible to meet our customers' needs in a timely, courteous, and helpful manner. To always remember that our customers are our life's blood and our reason for existence, that serving them is not an imposition on our time; it is the reason we are here.
- Strive for improvement day in and day out in everything we do.
- Maintain and enhance cooperative relationships with our customers to better serve the health care needs of the beneficiary communities we serve.
B. Expectations and Responsibilities of Employees or Non-employees
Godwin expects all employees and non-employees to become familiar with and comply with its compliance plan. If an employee or non-employee becomes aware of a situation that violates appropriate legal or ethical standards, he/she is required to bring it to the attention of the appropriate persons in accordance with this plan so that it can be resolved effectively. Godwin expects full cooperation with regards to the investigation of possible violations of Godwin policies. Adherence to these policies will be considered in employee evaluations.
III. Policies
A. Compliance with Timesheet Guidelines
Employees are responsible for following the guidelines regarding timesheets to facilitate accurate billing. Employees who fail to comply with timesheet guidelines will be considered in violation of the compliance plan and may be subject to the sanctions provided in this plan. [1]Non-employees include independent contractors and other third parties.
B. Reviewing Timesheets and Schedules
Where appropriate, Godwin has provided a work site supervisor at each location site. The work site supervisor is responsible for reviewing completed timesheets. Where there is no site supervisor, the Godwin Corporate Office works with the Program Manager to ensure timesheets are correct.
C. Billing for Reimbursement
Billing managers are only permitted to submit invoices after all of the appropriate supporting documents for hours worked and services rendered are provided. All documentation should be provided in a timely manner prior to billing to ensure that only accurate and properly documented services are billed.
IV. Compliance Officer
Godwin has designated compliance officer who may be reached via the Compliance Hotline at 1.877.4.GODWIN (1.877.446.3946). The overall role of the compliance officer is to monitor the compliance process. The primary duties of the compliance officer include:
- Overseeing and monitoring the implementation of the compliance plan
- Reporting on a regular basis to the CEO of Godwin on the progress of compliance concerns and resolutions and assisting the CEO in establishing methods to improve Godwin efficiency and quality of services, and to reduce Godwin vulnerability to fraud, abuse, and waste
- Periodically revising the plan in light of changes in the needs of the corporation, the law and policies and procedures of government
- Determining the appropriate approach to promote compliance with the program and detection of any potential violations, such as through hotlines and other fraud reporting mechanisms
- Developing, coordinating, and implementing an educational and training program that focuses on the elements of the compliance plan and seeks to ensure that all appropriate employees and management are knowledgeable and comply with applicable federal and states laws
- Ensuring that independent contractors and agents who furnish healthcare services to the hospitals are aware of the Godwin compliance plan with respect to scheduling, and billing
- Independently investigating and acting on matters related to compliance, including the flexibility to design and coordinate internal investigations and any resulting corrective action with all employees
- Conducting periodic audits of the compliance plan to identify problem areas and assisting in the reduction of those areas
- Maintaining a disclosure log that will keep a record of inquiries and resolutions with regards to compliance
- Developing policies and programs that encourage all employees or non-employees to report suspected fraud and other improprieties without fear of retaliation.
V. Reporting Compliance Concerns
Godwin encourages open communication of compliance concerns between employees and the compliance officer. As a result, confidentiality and non-retaliation policies have been implemented to support the reporting of alleged compliance violations. Godwin has also provided an anonymous hotline, 1.877.4.GODWIN (1.877.446.3946), for employees to raise compliance concerns directly to the compliance officer. This hotline number is available to all employees and is accessible 24 hours a day. Compliance concerns that are brought to the attention of the compliance officer will be resolved quickly and with every effort to maintain the privacy and confidentiality of the employee who has raised the concern. Any concerns that are brought to the attention of the compliance officer by an employee will not result in retaliation to that employee. The compliance officer will record each concern and its resolution in a disclosure log that may be reviewed periodically by either the compliance officer or the CEO of Godwin. At the request of the employee, the disclosure log will not identify the employee by name.
VI. Procedures for Investigation of Complaints
Reports of misconduct or noncompliance will be addressed immediately by the compliance officer. Prompt steps will be taken to investigate the conduct in question to determine whether a material violation of applicable law or the compliance plan has occurred.
VII. Enforcement of Compliance Plan
Reports of misconduct or noncompliance will be addressed immediately by the compliance officer. Prompt steps will be taken to investigate the conduct in question to determine whether a material violation of applicable law or the compliance plan has occurred.
