Compliance Policy #904
Boulder Community Hospital will use due care not to delegate substantial discretionary authority to individuals whom the Hospital knows, or should know through the reasonable exercise of due diligence, has a propensity to engage in illegal activities.
Responsibility: All Hospital Personnel
Requirements for All Employees and Independent Contractors The Hospital shall not employ or contract with any person or entity who has been convicted of a criminal offense related to health care or who has been debarred, excluded or is otherwise ineligible from participating in any federal or state health care program, including without limitation, Medicare, Medicaid and CHAMPUS or TRICARE, within the past ten years. Persons excludednfrom a federal or state health care program who have been reinstated may be considered for employment upon proof of reinstatement. All applicants for employment and potential independent contractors shall be required to discloseany criminal conviction of a health care offense and any exclusion from a federal or state health care program. Failure to disclose such information, whether intentional or inadvertent or the provision of false or misleading information, shall be grounds for immediate termination of the employment or independent contract relationship.
New Employee/Independent Contractor Screening
In addition to the regular employment screening requirements for all applicants for employment or other contractual relationships at the Hospital, applicants for the positions listed below shall be subject to a background
check as described in this policy:
- All Department Directors, Assistant Department Directors and Managers
- All members of Senior Management, including Chief Executive Officer and Vice Presidents
- All Physician Medical Directors as designated by the Compliance Committee
- All billing supervisors and other billing personnel with discretionary authority to make billing decisions
- Any other persons who have discretionary authority to make decisions that may involve compliance with the law or oversight over any aspect of the Hospital's compliance program, as designated by the Compliance Committee orthe Director of Human Resources.
The background check required by this policy shall may include any of at least the following, which are appropriate for the position in question, as determined by the Director of Human Resources or the Compliance Committee:
1. Verification of licenses
2. Verification of education
3. Verification of past employment
4. Verification of all references provided by the applicant (A specific number of personal and professional references may be required for certain positions)
5. Verification of continuing education and appropriate education and training for the position applied for
6. Credit check
7. Criminal background check
8. Query of the following databases, as applicable:
- Cumulative Sanction Report published by the Office of Inspector General
- General Services Administration list of debarred federal contractors
- Health Care Fraud and Abuse Data Collection data base
- National Practitioner Data Bank
In the event the background check reveals any evidence of previous improper conduct or a propensity to commit such conduct, the Hospital shall not employ or contract with the individual without the written approval of the Compliance Officer.
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