ZoMed & CODE OF CONDUCT ZoMed Home Health Agency

Topic: BusinessTeamwork
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Last updated: September 17, 2019

ZoMed Home Health Agency of Austin, Texas aims to provideand promote high quality community home health care.

This voluntary complianceplan maintains our commitment to patient-centered care while adhering to allapplicable Federal and state laws.  The seven elements of ZoMed Home Health Agency complianceplan arei: 1.    Commitment to Compliance & Code of Conduct  2.    Compliance Oversight 3.    Training and Education  4.    Communication 5.    Auditing and Monitoring 6.

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    Responding to Potential Compliance Issues 7.    Disciplinary Guidelines  COMMITMENT TOCOMPLIANCE & CODE OF CONDUCT ZoMed Home Health Agency is committed to ethical conductwithin the workplace. The agency is an equal employment opportunity employer. Theagency does not discriminate on any basis prohibited by applicable federaland/or state law including race, creed, color, disability, sex, age, ornational origin.

 The agency aims to provide a positive working environmentfor all employees and will not tolerate workplace harassment or misconduct. Itis the policy of the agency to provide a working environment that is free from inappropriateand/or illegal harassment, sexual misconduct, hazing or violence. The agencywill respond accordingly to any incidents that are reported, including anydisciplinary action deemed necessary. ZoMed Home Health Agency and all of its employees will treatpatients with the utmost respect and dignity.

The agency will not discriminatethe treatment of patients based on race, creed, color, disability, sex, age, ornational origin.   COMPLIANCEOVERSIGHT The commitment to compliance for ZoMed Home Health Agency isoverseen and managed by a Corporate Compliance Officer and a ComplianceCommittee. The ZoMed Home Health Agency designates their Chief HumanResources Officer (CHRO) to serve as the Corporate Compliance Officerii.The Compliance Officer will be responsible for overseeing and coordinating allcompliance activities for the agency including but not limited toi: 1.    Oversee that all employees receive education andtraining regarding the Code of Conduct2.    Oversee that all employees receive propercompliance program training3.

    Oversee that all employees receive appropriatecompliance policies and procedures applicable to their job responsibilities4.    Revise the compliance plan as needed to improvethe organization or as changes in the law occur5.    Coordinate with the Compliance Committee tomonitor and evaluate monthly/quarterly compliance audits and reviews6.    Coordinate and implement programs that encourageall agency staff to report any suspected instance of wrongdoing without fear ofretaliation7.    Discipline any employees who do not adhere tothe code of conduct  ZoMed Home Health Agency will designate a ComplianceCommittee to assist the Compliance Officer with the implementation of thecompliance program.

The committee will meet monthly to assess and analyze anyareas of risk. The committee will assist the Compliance Officer and analyze complianceaudits/reviews as requested. The committee will also assist the ComplianceOfficer with any reports of wrongdoing from agency staff.    TRAINING ANDEDUCATION  ZoMed Home Health Agency requires all employees to attendcompliance training upon hire and on an annual basis thereafter.

The trainingwill include the Code of Conduct, the Compliance Plan, and any compliancepolicies and procedures applicable to each employee’s responsibilities. Agencyemployees will be informed on reporting compliance violations and anysubsequent disciplinary actions. Participation and completion of compliancetraining is a condition of continued employment.

On the recommendation of theOffice of Inspector General, the agency will require at least 3 hours ofcompliance training per year for each current employee.i The Compliance Officer and Compliance Committee will beresponsible for implementing corrective actions if concerns arise from anyaudits, reviews or reports of compliance violations. The Compliance Officerwill also be responsible for confirming that each employee signs a writtenacknowledgment upon completion of compliance training. The Compliance Committeewill assist the Compliance Officer in assuring the records are accurate and upto date.   COMMUNICATION The Compliance Officer and Compliance Committee will see toit that all agency employees have access to written and electronic forms of thecompliance policies and procedures. A written copy of the agency’s Compliance Planwill be distributed to all new hire employees at orientation.

In addition, allagency managers and supervisors will keep a written copy of the Compliance Planin their respective offices should an employee need access. Agency staff willalso be provided with compliance information by means of bulletin boards,e-mails, company newsletters and links to information on the ZoMed webpage.  ZoMed Home Health Agency, under the guidance of theCompliance Officer, will establish a procedure for employees to seekclarification regarding any questions, concerns, or confusion of a certainpolicy.  Agency employees are encouraged to report any concerns totheir supervisor or to the Compliance Officer without fear of retaliation. Theagency takes great concern for protecting its employees and providing a safeworkplace environment. If an employee is not comfortable reporting to asupervisor or to the Compliance Officer directly, they can anonymously report anyconcerns or compliance violations using the compliance hotline at (800) 123-4567. The Compliance Officer will document and preserve allrecords of wrongdoing, investigations, and their results in accordance with thelaw. The agency is committed to maintaining proper documentation and promptinvestigation of any reported violations.

Failure to report any misconduct is aviolation of the agency’s Compliance Plan.  AUDITING ANDMONITORING The Compliance Officer will be responsible for conductingperiodic reviews of ZoMed Home Health Agency adherence to the Compliance Plan.The audits may be through internal or external personnel as deemed necessary bythe Compliance Officer. The Compliance Officer will review all audit results withthe Compliance Committee and coordinate any necessary corrective measures.  The Compliance Officer will see to it that monitoringefforts ensure the agency’s compliance with laws governingiii: CodingAgency billing staff must ensure that the diagnosis andprocedure codes for the agency’s home health services submitted on areimbursement claim are in compliance with all applicable coding rules andguidelines including any International Classification of Disease (ICD),Current Procedural Terminology (CPT), CMS-HCPCS, or revenue codes. Billing fraud and false claimsThe agency will refrain from billing fraud including but notlimited to: billing for items or services not provided as claimed; submittingclaims for services or medical supplies that are not necessary; duplicatebilling; duplicate services; unbundling; billing for substandard care; andupcoding the level of service provided. Anti-Kickback arrangementsThe agency will refrain from participating and will condone receivinganything of value to influence referrals or gain business. Any agency employeeinvolved in endorsing and/or accepting kickbacks may be terminated immediately.

 DocumentationThe agency will ensure that all home health service recordsrequired by federal and/or state law are provided in a timely manner prior tobilling so that accurately documented home health services are billed. Theagency staff will ensure that such records are maintained, organized, and madeavailable for review. All records will be stored in a safe place and made availableas needed.

 Reasonable and necessary servicesThe agency will only bill for claims that are reasonable andnecessary given the patient’s condition. The agency is mindful that Medicarewill only pay for services that meet the Medicare definition of reasonable andnecessary. MarketingThe agency will adhere to truthful, informative, andnon-deceptive marketing. Patient privacyAll agency employees must adhere to patient privacy rules asset by the Health Insurance Portability and Accountability Act (HIPAA) and theHealth Information Technology for Economic and Clinical Health Act (HITECH)iv.    RESPONDING TOPOTENTIAL COMPLIANCE ISSUES The Compliance Officer will review any violations ormisconduct that is reported. Upon initial assessment, the Compliance Officerwill determine if the violation reported raises any compliance issues.

TheCompliance Officer will then conduct an appropriate investigation and providethe analysis results to the Compliance Committee for further review.  The Compliance Officer, in coordination with the ComplianceCommittee, will take appropriate disciplinary action based on the results ofthe investigation.  DISCIPLINARYGUIDELINESv ZoMed Home Health Agency will not tolerate any employee whoknowingly violates and/or fails to comply with the standards established in theCompliance Plan.

The agency will also not tolerate any employee who fails toreport wrongdoing or misconduct.  The employee’s direct supervisor or manager will be responsiblefor taking any disciplinary measures deemed appropriate by the ComplianceOfficer and the Compliance Committee. These disciplinary measures can include butare not limited to: issuing a warning, issuing a letter of reprimand,modification of assigned duties and/or privileges, employee suspension, oremployee termination.  ZoMed Home Health Agency strives to cultivate a culture of compliance.

We are committed to providing patient-centered care in an honest and ethicalmanner. The agency’s Compliance Plan reaffirms our commitment to the highestlevel of patient care consistent with all Federal and state governingstandards. We appreciate the collaborative effort of all ZoMed Home Healthagency employees to ensure our culture of compliance.

The agency supports a commitmentto continuous improvement in compliance and patient care. i U.S.Dept.

of Health and Human Services. Office of Inspector General. OIGCompliance Program for Individual and Small Group Physician Practices. By JuneGibbs Brown. 2000. Compliance 101:Compliance Education Materials. Web.

20 January 2018.ii Charan,Ram, et al. “People Before Strategy: A New Role for the CHRO.” Harvard Business Review, no. 7-8, 2015,p. 62. EBSCOhost, ezproxy.lsus.


aspx?direct=true&db=edsggo&AN=edsgcl.420057877&site=eds-live.iii Iglehart, John K. “The ACAsNew Weapons against Health Care Fraud.” New England Journal ofMedicine, vol. 363, no.

4, 22 July 2010, pp.304–306.,doi:10.1056/nejmp1007088.iv Blumenthal, David. “Implementation of theFederal Health Information Technology Initiative.” New England Journal ofMedicine, vol. 365, no.

25, 22 Dec. 2011, pp.2426–2431.

, doi:10.1056/nejmsr1112158.v J.J.Keller &, Associates. Employment Law Essentials: YourA to Z Guide to HR Compliance.

J. J. Keller & Associates, Inc,2011. EBSCOhost, ezproxy.lsus.


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