Overview and Reporting Options
Clinical & Support Options, Inc. (CSO, Inc.), and its affiliates,
seeks to conduct itself in accordance with the highest level of business
and community ethics and in compliance with applicable governing laws. CSO, Inc. recognizes the problems that both deliberate and
accidental misconduct in the health care industry can pose to society.
CSO, Inc. is committed to ensuring that it operates under the
highest ethical and moral standards and that its activities comply with
applicable laws.
CSO, Inc.’s Compliance Plan (the "Plan") has been developed
in accordance with applicable law, with guidance from state and federal
authorities when available, including the Federal Sentencing Guidelines.
The Plan focuses on the prevention of fraud, abuse and waste in federal,
state and private health care plans.
The scope of the Plan may be expanded in the future to cover
other areas of compliance to which CSO, Inc. is subject.
With this Plan, CSO, Inc. will seek to promote full compliance
with all legal duties applicable to it, foster and assure ethical
conduct, and provide guidance to each employee and agent of CSO, Inc.
for his/her conduct. The
procedures and standards of conduct contained in this Plan are intended
to generally define the scope of conduct which the Plan is intended to
cover and are not to be considered as all inclusive.
This Plan is intended to prevent accidental and intentional
noncompliance with applicable laws, to detect such noncompliance if it
occurs, to discipline those involved in noncompliant behavior, to remedy
the effects of non-compliance and to prevent future noncompliance. This
Compliance Plan is a "living document" and will be updated
periodically to keep CSO, Inc.’s employees and agents informed of the
most current information available pertaining to compliance requirements
in the health care industry.
The Plan, in it’s entirety, is published on this website and
every CSO employee or agent is advised to review it. Please read it
carefully. What follows is a description of the temporary reporting
mechanisms. It is repeated in Section VII.C of the Plan.
All
questions and concerns regarding compliance with the standards set forth
in this Plan shall be directed to or brought to the attention of the
Acting Compliance Officer. All CSO Employees and CSO Agents must fully
cooperate and assist the Acting Compliance Officer as required in the
exercise of his or her duties. If a CSO Employee or CSO Agent is
uncertain whether specified conduct is prohibited, the CSO Employee or
CSO Agent shall utilize the established reporting mechanism to contact
the Acting Compliance Officer for guidance prior to engaging in such
conduct. Reporting Mechanism A temporary reporting mechanism has been established. The mechanism will serve as a reporting option for CSO Employees and CSO Agents with information about suspected misconduct. Through this mechanism, questions about compliance standards and legal duties should be forwarded to the Acting Compliance Officer, who will respond or direct a response from an appropriate person or persons within CSO. · The Acting Compliance Officer shall investigate all reports of suspected misconduct received through the reporting mechanism. · The Acting Compliance Officer shall refer all legal issues to CSO outside counsel. · The Acting Compliance Officer reports directly to the CSO Board of Directors on matters that require additional investigation or legal reference. Reporters who wish to remain anonymous will be provided with an identification number. This identification number may be used if additional information becomes available or if further questioning is necessary. CSO cannot guarantee anonymity in the event of a government investigation or legal action. Any CSO Employee or CSO Agent who develops concerns over unethical practices, improper employee conduct, the integrity of CSO's billing/coding practices or other improper practices described throughout this Plan, is encouraged to report such concern through the reporting mechanism or directly to the Acting Compliance Officer. Federal law prohibits retribution against any employee or agent making “good faith” reports of suspected non-compliance. Any CSO Employee or CSO Agent who makes an intentionally false statement or otherwise intentionally misuses the reporting mechanism may be subject to discipline, up to and including termination of employment or contractual status. This website, in addition to staff training and immediate access to the Acting Compliance Officer, will provide a means of communicating information to employees regarding billing and other compliance issues.
Reporting Options Any CSO employee or agent may contact the Acting Compliance Officer, Practice Management Associates, in the following ways: 1.
Via internet e-mail at CSOCompliance@aol.com
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