Corporate Compliance

Tip: Determine whether your new-employee policy measures up

Compliance Monitor, April 21, 2004

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Make sure your hospital's policy for new employees includes the following provisions:

1. The hospital conducts a reasonable background investigation, including reference checks, on every new employee who has the authority to make decisions involving compliance with the law or compliance oversight.

2. Applicants must disclose any criminal conviction or exclusion action.

3. Hospital policies prohibit hiring an individual who has recently been convicted of a healthcare-related criminal offense, or who is listed as debarred, excluded, or otherwise ineligible for participation in government healthcare programs.

4. The hospital terminates employment or contracts with current employees or independent contractors who are convicted, debarred, or excluded from government healthcare programs.

This tip was adapted from the manual Hospital Auditing and Monitoring: Sample programs for key risk areas. This is a step-by-step, practical manual that offers sample audit programs for the most troublesome areas a hospital must audit.

For more information or to order, click here.



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