Cooperation with Government

Authorities

Compliance Policy #909

It is the policy of Boulder Community Hospital to promptly self-report, as required by law and as otherwise appropriate, any violation of a criminal, civil or administrative law and to cooperate appropriately with enforcement and regulatory authorities in the investigation of such violations.

Responsibility: All Hospital Personnel

PROCEDURE

Self-Reporting

In the event the Hospital discovers credible evidence of misconduct and after a reasonable inquiry, has reason to believe that the misconduct violates criminal, civil or administrative laws, the Hospital shall report the misconduct to the appropriate governmental authority having jurisdiction over the matter if such report is required by law or is otherwise appropriate under the circumstances, as determined by the Compliance Officer and/or Chief Executive Officer.  The Hospital shall make such report within a reasonable period of time and shall, where feasible, use its best efforts to make suchreports within sixty (60) days (or less, if practicable), after determining that there is credible evidence of a  violation.

As a general rule, the Hospital shall not report a violation  unless and until the Hospital has completed its internal  investigation of the matter.  The Hospital, may however,  report a violation prior to completion of the investigation  if the Hospital determines, in consultation with legal counsel, that the violation is supported by credible  evidence and is serious enough to warrant immediate  notification to governmental authorities.

All reports made to governmental entities on behalf of the  Hospital shall be made by the Compliance Officer or Chief  Executive Officer.  The Compliance Officer or Chief Executive Officer shall consult with legal counsel to
determine whether the misconduct constitutes a violation of  law and whether a report to governmental authorities is required by law or is otherwise appropriate.

Overpayments

The Hospital shall promptly refund any payments made by state or federal agencies, or other health care payers as appropriate, which were made erroneously and of which the Hospital is aware.  Such refunds shall be made as
required by law or otherwise appropriate and shall be made within a reasonable period of time after the Hospital discovers the overpayment or within such time as may be prescribed by law.  Any refund by the Hospital of overpayments from government  agencies shall be reported to the Compliance Officer prior to submission of the overpayment.  The Compliance Officer shall take any necessary and appropriate steps to investigate the basis for such overpayments to determine whether a violation of applicable law has occurred.

Cooperation with Government Authorities

The Hospital shall cooperate appropriately with government authorities in the investigation of any alleged misconduct  by the Hospital or its employees or agents.  The Compliance Officer shall be responsible for coordinating the Hospital's  response to any inquiry from a governmental agency or investigation by such agency.  The Compliance Officer may delegate that responsibility to another management official within the Hospital, subject to oversight by the Compliance Officer.

Inquiries to Government Agencies

Any employee who makes an inquiry to any government agency on behalf of the Hospital with respect to any obligation of the Hospital shall document such inquiry, including the date, the name of the person contacted, and the information provided.


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