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program that includes, among other things, a compliance officer, compliance committee, written standards of conduct, compliance education and training, a mechanism for individuals to report incidents ofnon-compliance, screening programs for ineligible persons, and removal requirements for ineligible
must be reviewed, assessments that must be completed, sub-certifications that must be obtained, etc. prior to the certifying employee making the required certification). freedom - corporate integrity agreement b. written standards within days after the effective date, freedom shall develop and implement...
https://www.oig.hhs.gov/fraud/cia/agreements/Freedom_Health_Inc_and_Optimum_Healthcare_Inc_05112017.pdf