DISCIPLINARY, AUDIT & RISK ASSESSMENT, EXCLUSION AND DRA POLICIES

DISCIPLINARY POLICY

Employees and contractors will be subject to disciplinary action, up to and including termination, if they:

  • Fail to participate in the Compliance Program with good faith
  • Fail to report incidents of non-compliance
  • Fail to assist in the resolution of a compliance issue
  • Participate in a non-compliant behavior
  • Encourage, direct, facilitate or permit non-compliant behavior

AUDIT & RISK ASSESSMENT

Achieve Beyond has implement internal audit & risk assessment protocols for each of its programs to gauge quality, identify overpayments/underpayments, and program strengths and weaknesses.

Internal assessments include review of patient files, billing data, provider/personnel files, and patient satisfaction surveys.

Corrective Action Plans are developed to repair program deficiencies, billing errors, clinical issues and other possible risks.

Incidents of Non-Compliance identifying are investigated per the Investigations Policy.

Exclusion List Policy

On a monthly basis, all employees/contractors of Achieve Beyond are screened thru several Exclusion Lists: 

Office of Inspector General, U.S. Department of Health and Human Services
http://exclusions.oig.hhs.gov/

New York State of Medicaid Inspector General
http://www.omig.ny.gov/data/content/view/72/52/

New Jersey Disqualified Providers
http://nj.gov/comptroller/divisions/medicaid/disqualified/

Connecticut Quality Assurance Administrative Actions List
http://portal.ct.gov/DSS/Quality-Assurance/Quality-Assurance-Administrative-Actions-List

Maryland Sanctioned Providers
https://mmcp.health.maryland.gov/Documents/Maryland%20Sanctioned%20Providers/maryland_sanctioned_providers0318.pdf

California Medi-Cal Suspended and Ineligible List
http://files.medi-cal.ca.gov/pubsdoco/SandILanding.asp 

Any employee/contractor that is an Excluded Party will be terminated immediately. Achieve Beyond will refund all related funds concerning the employee/contractor to the payer.

DRA POLICY

Achieve Beyond provides all employees and contractors with detailed information about:

  • the federal False Claims Act
  • the federal administrative remedies associated with the False Claims Act
  • state laws pertaining to civil or criminal penalties for false claims and statements
  • whistleblower protections provided under federal and state laws; and
  • the role of federal and state laws in preventing and detecting fraud, waste and abuse

The company provides a state-specific DRA notice containing a description of Achieve Beyond’s compliance program and a DRA-compliant explanation of the federal and state fraud and abuse laws applicable in the state in which the employee or contractor will provide work for Achieve Beyond.

The state-specific DRA Notices can be found at: https://www.achievebeyondusa.com/index.php/856

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