ZoMed Home Health Agency of Austin, Texas aims to provide
and promote high quality community home health care. This voluntary compliance
plan maintains our commitment to patient-centered care while adhering to all
applicable Federal and state laws.
The seven elements of ZoMed Home Health Agency compliance
Commitment to Compliance & Code of Conduct
Training and Education
Auditing and Monitoring
Responding to Potential Compliance Issues
COMPLIANCE & CODE OF CONDUCT
ZoMed Home Health Agency is committed to ethical conduct
within the workplace. The agency is an equal employment opportunity employer. The
agency does not discriminate on any basis prohibited by applicable federal
and/or state law including race, creed, color, disability, sex, age, or
The agency aims to provide a positive working environment
for all employees and will not tolerate workplace harassment or misconduct. It
is the policy of the agency to provide a working environment that is free from inappropriate
and/or illegal harassment, sexual misconduct, hazing or violence. The agency
will respond accordingly to any incidents that are reported, including any
disciplinary action deemed necessary.
ZoMed Home Health Agency and all of its employees will treat
patients with the utmost respect and dignity. The agency will not discriminate
the treatment of patients based on race, creed, color, disability, sex, age, or
The commitment to compliance for ZoMed Home Health Agency is
overseen and managed by a Corporate Compliance Officer and a Compliance
The ZoMed Home Health Agency designates their Chief Human
Resources Officer (CHRO) to serve as the Corporate Compliance Officerii.
The Compliance Officer will be responsible for overseeing and coordinating all
compliance activities for the agency including but not limited toi:
Oversee that all employees receive education and
training regarding the Code of Conduct
Oversee that all employees receive proper
compliance program training
Oversee that all employees receive appropriate
compliance policies and procedures applicable to their job responsibilities
Revise the compliance plan as needed to improve
the organization or as changes in the law occur
Coordinate with the Compliance Committee to
monitor and evaluate monthly/quarterly compliance audits and reviews
Coordinate and implement programs that encourage
all agency staff to report any suspected instance of wrongdoing without fear of
Discipline any employees who do not adhere to
the code of conduct
ZoMed Home Health Agency will designate a Compliance
Committee to assist the Compliance Officer with the implementation of the
compliance program. The committee will meet monthly to assess and analyze any
areas of risk. The committee will assist the Compliance Officer and analyze compliance
audits/reviews as requested. The committee will also assist the Compliance
Officer with any reports of wrongdoing from agency staff.
ZoMed Home Health Agency requires all employees to attend
compliance training upon hire and on an annual basis thereafter. The training
will include the Code of Conduct, the Compliance Plan, and any compliance
policies and procedures applicable to each employee’s responsibilities. Agency
employees will be informed on reporting compliance violations and any
subsequent disciplinary actions. Participation and completion of compliance
training is a condition of continued employment. On the recommendation of the
Office of Inspector General, the agency will require at least 3 hours of
compliance training per year for each current employee.i
The Compliance Officer and Compliance Committee will be
responsible for implementing corrective actions if concerns arise from any
audits, reviews or reports of compliance violations. The Compliance Officer
will also be responsible for confirming that each employee signs a written
acknowledgment upon completion of compliance training. The Compliance Committee
will assist the Compliance Officer in assuring the records are accurate and up
The Compliance Officer and Compliance Committee will see to
it that all agency employees have access to written and electronic forms of the
compliance policies and procedures. A written copy of the agency’s Compliance Plan
will be distributed to all new hire employees at orientation. In addition, all
agency managers and supervisors will keep a written copy of the Compliance Plan
in their respective offices should an employee need access. Agency staff will
also 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 the
Compliance Officer, will establish a procedure for employees to seek
clarification regarding any questions, concerns, or confusion of a certain
Agency employees are encouraged to report any concerns to
their supervisor or to the Compliance Officer without fear of retaliation. The
agency takes great concern for protecting its employees and providing a safe
workplace environment. If an employee is not comfortable reporting to a
supervisor or to the Compliance Officer directly, they can anonymously report any
concerns or compliance violations using the compliance hotline at (800) 123-4567.
The Compliance Officer will document and preserve all
records of wrongdoing, investigations, and their results in accordance with the
law. The agency is committed to maintaining proper documentation and prompt
investigation of any reported violations. Failure to report any misconduct is a
violation of the agency’s Compliance Plan.
The Compliance Officer will be responsible for conducting
periodic reviews of ZoMed Home Health Agency adherence to the Compliance Plan.
The audits may be through internal or external personnel as deemed necessary by
the Compliance Officer. The Compliance Officer will review all audit results with
the Compliance Committee and coordinate any necessary corrective measures.
The Compliance Officer will see to it that monitoring
efforts ensure the agency’s compliance with laws governingiii:
Agency billing staff must ensure that the diagnosis and
procedure codes for the agency’s home health services submitted on a
reimbursement claim are in compliance with all applicable coding rules and
guidelines including any International Classification of Disease (ICD),
Current Procedural Terminology (CPT), CMS-HCPCS, or revenue codes.
Billing fraud and false claims
The agency will refrain from billing fraud including but not
limited to: billing for items or services not provided as claimed; submitting
claims for services or medical supplies that are not necessary; duplicate
billing; duplicate services; unbundling; billing for substandard care; and
upcoding the level of service provided.
The agency will refrain from participating and will condone receiving
anything of value to influence referrals or gain business. Any agency employee
involved in endorsing and/or accepting kickbacks may be terminated immediately.
The agency will ensure that all home health service records
required by federal and/or state law are provided in a timely manner prior to
billing so that accurately documented home health services are billed. The
agency staff will ensure that such records are maintained, organized, and made
available for review. All records will be stored in a safe place and made available
Reasonable and necessary services
The agency will only bill for claims that are reasonable and
necessary given the patient’s condition. The agency is mindful that Medicare
will only pay for services that meet the Medicare definition of reasonable and
The agency will adhere to truthful, informative, and
All agency employees must adhere to patient privacy rules as
set by the Health Insurance Portability and Accountability Act (HIPAA) and the
Health Information Technology for Economic and Clinical Health Act (HITECH)iv.
POTENTIAL COMPLIANCE ISSUES
The Compliance Officer will review any violations or
misconduct that is reported. Upon initial assessment, the Compliance Officer
will determine if the violation reported raises any compliance issues. The
Compliance Officer will then conduct an appropriate investigation and provide
the analysis results to the Compliance Committee for further review.
The Compliance Officer, in coordination with the Compliance
Committee, will take appropriate disciplinary action based on the results of
ZoMed Home Health Agency will not tolerate any employee who
knowingly violates and/or fails to comply with the standards established in the
Compliance Plan. The agency will also not tolerate any employee who fails to
report wrongdoing or misconduct.
The employee’s direct supervisor or manager will be responsible
for taking any disciplinary measures deemed appropriate by the Compliance
Officer and the Compliance Committee. These disciplinary measures can include but
are not limited to: issuing a warning, issuing a letter of reprimand,
modification of assigned duties and/or privileges, employee suspension, or
ZoMed Home Health Agency strives to cultivate a culture of compliance.
We are committed to providing patient-centered care in an honest and ethical
manner. The agency’s Compliance Plan reaffirms our commitment to the highest
level of patient care consistent with all Federal and state governing
standards. We appreciate the collaborative effort of all ZoMed Home Health
agency employees to ensure our culture of compliance. The agency supports a commitment
to continuous improvement in compliance and patient care.
Dept. of Health and Human Services. Office of Inspector General. OIG
Compliance Program for Individual and Small Group Physician
Practices. By June
Gibbs Brown. 2000. Compliance 101:
Compliance Education Materials. Web. 20 January 2018.
Ram, et al. “People Before Strategy: A New Role for the CHRO.” Harvard Business Review, no. 7-8, 2015,
p. 62. EBSCOhost,
iii Iglehart, John K. “The ACAs
New Weapons against Health Care Fraud.” New England Journal of
Medicine, vol. 363, no. 4, 22 July 2010, pp.
iv Blumenthal, David. “Implementation of the
Federal Health Information Technology Initiative.” New England Journal of
Medicine, vol. 365, no.
25, 22 Dec. 2011, pp.
Keller &, Associates. Employment Law Essentials: Your
A to Z Guide to HR Compliance. J. J. Keller & Associates, Inc,