IDENTIFYING AND REPORTING POSSIBLE INCIDENTS OF NON-COMPLIANCE

What and How to Report

Billing

Billing Related Issues are amongst the most serious Compliance Issues

Examples include:

  • A provider asking a parent to sign blank or inaccurate session notes
  • Suspicious signatures on session notes
  • Parent reports that provider has been absent, yet submitted session notes do not indicate attendance issues
  • Submission of notes that detail events that never happened
  • Submission of “False Claims”

A False Claim is a claim that a provider knows is unwarranted, submitted with reckless disregard for accuracy & submitted with deliberate ignorance of public guidelines.

Breach of Patient Confidentiality

Achieve Beyond has legal and contractual obligations to protect the identity of its patients.


Examples include:

  • Lost or stolen files
  • Unauthorized parties accessing files
  • Inappropriate/unsecure transmission of patient data, including e-mails and text messages


Some notes on maintaining confidentiality of Patient Data:

  • Files should be kept in a locked cabinet/room
  • Files should be transported in a locked case
  • Files & Devices should never be left unattended in a car
  • Computers/Lap Tops should be password protected (6 characters with 1 capital letter & 1 number)
  • Tablets & Mobile Phones should be set to lock after 5 minutes of inactivity
  • External Hard Drives, Flash Drives and CDs should be PW Protected
  • Only transmit patient data via e-mail between achievebeyondusa.com email addresses
  • Do not SMS Text detailed patient data
  • Faxes must include Confidentiality Notice (e-faxing from your AB e-mail provides this protection)

IF AN ELECTRONIC DEVICE (WHETHER COMPANY OR PERSONAL) CONTAINING PATIENT OR COMPANY INFORMATION IS LOST OR STOLEN, INFORM THE IT DEPARTMENT & THE COMPLIANCE OFFICER IMMEDIATELY.

Other Reportable Incidents

  • Abuse/Neglect – all staff members are designated reporters of patient abuse/neglect
  • Health and Safety – staff not following Universal Precautions procedures (cleaning therapy tools/toys, washing hands, wearing gloves)
  • Patient or Provider Injuries
  • Parent/Patient Complaints
  • Manager/Staff Member failing to follow company policies or program regulations
  • Inquiries from Regulators/Gov’t Officials
  • Kickbacks
  • Conflicts of Interest
  • Immigration Issues
  • Discrimination
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