Compliance
DCO is committed as a Company to act with integrity in all that we do. That is why we created a Compliance Program that sets standards for conduct and encourages ethical behavior. We continually aim for improvements in our practices, policies and environment to make the Compliance Program as effective as possible.
At the core of DCO's Compliance Program is the Company's two-fold commitment to promote ethical behavior and comply with all applicable laws and regulations. DCO's Compliance Program contains the seven elements widely recognized as a fundamental for an effective e compliance program, including:
Establishing a Formal Structure for Overseeing Compliance
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DCO has assigned the authority and responsibility for overseeing compliance activities to the Compliance Officer & created a Compliance Department.
Implementing Written Standards and Policies and Procedures to Promote Compliance
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DCO has developed the Code of Conduct, and the Compliance Program Policies and Procedures, to help promote and the company’s integrity and ethical principles as well as, the Company’s compliance with all applicable laws and regulations. DCO will maintain a complete set of policies to support this function.
Conducting Effective Training and Education Designed to Promote Compliance
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The Compliance Program requires a partnership between DCO and its employees. As partners, both DCO and its employees have certain roles and responsibilities. For example, DCO will make reasonable efforts to provide employees with access to information about the laws that govern the operation of DCO and its Medicare Advantage program. Similarly, employees must make every reasonable effort to understand the rules. As a result, DCO will conduct (or cause its agents to conduct) periodic training programs that focus on the Medicare Advantage program requirements and prevention of fraud and abuse and other related topics. Employees will be required to attend these sessions.
Developing Effective Lines of Communication, Including Mechanisms for Reporting Suspected Non-Compliance with Applicable Laws and Regulations, the Code of Conduct, and/or DCO Policies and Procedures
- DCO requires that all directors, officers, employees to report good faith concerns they may have regarding actual or suspected instances of non-compliance with laws and regulations, the Code of Conduct or the DCO Compliance Policies and Procedures.
- DCO makes all reasonable efforts to maintain the confidentiality of any individual who reports suspected misconduct to the extent consistent with the Company’s reporting obligations and the need to investigate the potential non-compliance.
- DCO prohibits retribution or retaliation against anyone who, in good faith, reports suspected non-compliance with laws and regulations, the Code of Conduct, or in DCO’s Compliance Policies and Procedures.
Conducting Internal Auditing and Monitoring
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As part of its Compliance Program, DCO will periodically monitor and audit various activities and departments to promote compliance with laws and regulations, and CMS regulation.
Responding Promptly to Detected Problems and Undertaking Appropriate Corrective Action
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When an internal investigation substantiates a compliance issue, the Compliance officer shall promptly initiate appropriate corrective action, in consultation with the Board of Directors, as appropriate.
Enforcing Standards through Well-Publicized Disciplinary Guidelines
- Individuals who are determined to have violated laws and regulations, DCO’s Code of Conduct, or DCO’s Compliance Policies and Procedures will be subject to corrective actions. The nature of the corrective actions will depend on the nature, severity, and frequency of the violation, and may result in disciplinary action up to and including termination of employment and potential referral to law enforcement.
- The Implementation of the Compliance Program provides many benefits to DCO as well as its employees. DCO’s Compliance Program demonstrates its commitment to responsible corporate conduct, establishes control mechanisms to monitor internal departments and external delegated entities to ensure compliance with regulations, reinforces employees, providers, and beneficiaries to report potential problems and cases of fraud, waste and abuse, and instructs employees, providers, and beneficiaries of their obligation to report cases of potential fraud, waste and abuse to CMS, OIG, and/or other law enforcement agencies as appropriate.
Compliance Program
DCO has established a Compliance Program to help its employees and agents deal with the complex legal obligations that govern DCO's health services operations. Employees or agents who observe another employee or agent violating these compliance standards are able to report the suspected violation anonymously. DCO does not tolerate any form of retaliation against a person, who, in good faith, reports an issue under DCO's Compliance Program and was not involved in the misconduct.
Reporting FWA and Compliance Issues
Direct Report
Compliance Office
If you suspect any potential case of fraud, waste or abuse or a potential compliance issue, you may report it by communicating the issue in the corresponding manner.
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Remember: You may report anonymously and retaliation is prohibited when you report a concern in good faith.
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All reports are confidential and may be anonymous. It is illegal to retaliate against or intimidate an employee when reporting suspected fraud, waste, or abuse.
Reporting to Medicare
Suspected cases of Medicare fraud may also be reported directly to the Health and Human Services Office of the Inspector General in writing or by phone:
US Department of Health and Human Service
Office of Inspector General
ATTN: OIG HOTLINE OPERATIONS
PO Box 23489
Washington, DC 20026
Phone: 1-800-HHS-TIPS(1-800-447-8477)