Unit Implementation
Each Unit may, as deemed appropriate by the Unit Compliance Officer in conjunction with the Dean of the School or the President of the Clinical Unit, develop a compliance plan and shall appoint a physician or other faculty leader and an administrator who will assist in the implementation and monitoring of the Unit’s plan. Before becoming effective, the unit compliance plan shall be reviewed and approved by the Chief Compliance Officer. Each Unit’s compliance plan shall include, at a minimum:
- Written policies and procedures for activities undertaken by the Unit which are beyond the scope of this plan;
- Coordination of mandatory education and training programs provided by the Unit Compliance Officer to address issues of general interest or of particular importance and interest to the Unit;
- A program for ensuring and documenting that all new Unit employees receive training with regard to compliance issues within three months of initial employment to instruct them as appropriate on billing practices and documentation requirements;
- Preparation of an annual report by the Unit for submission to the Unit Compliance Officer which describes the compliance activities completed within the department; 5. An annual assessment by the Unit of its compliance plan identifying necessary changes and specific compliance objectives for the succeeding year;
