SUBJECT: Anti-Kickback Statute Policy
APPROVED BY: Board of Directors
DATE EFFECTIVE: July 24, 2013
DATE REVISED: July 24, 2013
REVISION APPROVED BY: Board of Directors
REVISED EFFECTIVE DATE: July 24, 2013
MANUAL: Corporate Compliance, Clinical
Policy: This Anti-Kickback Statute Policy requires NTSOC’s compliance with the Federal Anti-Kickback Statute and analogous state laws. In addition, it is designed to ensure that all NTSOC employees and contractors understand:
- The elements of the Anti-Kickback Statute; and
- The obligation to report violations and/or seek guidance, where necessary.
This Policy is applicable to all NTSOC business transactions and practices that could implicate the Anti-Kickback Statute and to all NTSOC employees and contractors engaged in such transactions or practices.
Compliance with the Anti-Kickback Statute: NTSOC is committed to conducting its business transactions and practices in compliance with the Anti-Kickback Statute and analogous state laws. All NTSOC employees and contractors shall comply with the requirements of the Anti-Kickback Statute as well as all related NTSOC company policies and procedures. This means that NTSOC employees and contractors shall not give, receive, solicit or help arrange anything of value as part of the process of obtaining or making referrals in violation of the Anti-Kickback Statute or state law. NTSOC employees and contractors shall report suspected violations of the Anti-Kickback Statute and/or related company policies and procedures consistent with NTSOC Compliance Policies and the NTSOC Code of Conduct.
In addition, NTSOC employees and contractors may direct any questions regarding the Anti-Kickback Statute and related NTSOC company policies and procedures to the Compliance Officer or the Administrator. If, after discussions with these individuals where the response is not satisfactory, NTSOC employees and contractors should contact a member of the Board of Directors. If the complaint or questions involves the conduct of the Compliance Officer or Administrator, the employee or contractor should contact a member of the Board of Directors.
Failure to comply with this Policy may result in:
- disciplinary action, up to and including termination of employment, for Employees; or
- termination of the contractual arrangement, for Contractors.