2023 Board Resources

programs, including but not limited to the risks associated with the submission of claims for items and services furnished to Medicare and Medicaid program beneficiaries. This process will require Banner leaders to, at least annually, (A) identify and prioritize risks; (B) develop and implement audit work plans related to those identified risks; (C) develop corrective action plans, as necessary, in response to the audit plans; and (D) track the implementation of the corrective action plans in order to assess their effectiveness. VI. Disclosure Program Banner must maintain its current Disclosure Program that requires Covered Persons to report suspected violations of Banner’s Code of Conduct, Banner’s policies, and/or any laws or regulations relating to Federal health care programs. Banner must permit individuals to report outside their chain of command – at Banner, individuals can report compliance issues to their Compliance Officer, the Ethics & Compliance Department, or the ComplyLine (which allows anonymous reporting). Banner must emphasize its non-retaliation policy. VII. Ineligible Person Screening Banner must continue to screen all prospective Covered Persons against the OIG’s List of Excluded Individuals/Entities (LEIE) prior to engaging their services and all current Covered Persons on a monthly basis thereafter. VIII. Overpayment Policies and Procedures Banner must maintain its 60-day Report/Repay Overpayments policy that describes the identification, quantification, and repayment of overpayments received from a Federal health care program. Reporting Requirements of the CIA I. Event Reporting A. Government Investigation or Legal Proceeding Banner must notify the OIG within 30 days of discovering any ongoing investigation or legal proceeding conducted or brought by a government entity or its agents involving an allegation that Banner has committed a crime or has engaged in fraudulent activities. Banner must also provide notice within 30 days of the resolution of the matter as well as a description of the findings. B. Reportable Events Banner must notify the OIG within 30 days after determining that certain Reportable Events have occurred. These Reportable Events include a substantial overpayment; a matter that a reasonable person would consider a probable violation of criminal, civil, or administrative laws applicable to any Federal health care program for which penalties or exclusion may be authorized; the employment of or contracting with a Covered Person who is an ineligible person; or the filing of a bankruptcy petition. C. Changes in Operational Requirements of the CIA Banner is required to notify the OIG of certain changes to the operational requirements of the CIA within specified timeframes. Some of these changes include: (1) actions or changes that would affect the ability of the designated individual or committee (such as the Chief Compliance Officer, Area Compliance Program Director, Audit