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Imagine you are a compliance officer, and you have been informed of a situation that may constitute a breach of the Anti-Kickback Statute. One of

Imagine you are a compliance officer, and you have been informed of a situation that may constitute a breach of the Anti-Kickback Statute. One of the nursing homes in your chain has made a deal with a mobile X-ray company to provide services. The contract states that the nursing home "will not be charged for any of the services to Medicare Part A patients if the nursing home agrees to refer all their Medicare Part B patients to the same company for mobile X-rays. The X-ray company can then charge Medicare directly for the Part B services." The executive leadership has asked you to review and determine whether this contract is ethical and complies with the Anti-Kickback Statute.

  • Determine 4 types of evidence you want to collect and evaluate how they'll be useful to your investigation.
  • Identify 3 stakeholders who would be relevant tothe interview.
  • Create 3 questions that are pertinent to each of the stakeholders identified above.
  • Determine if the incident will need to be externally disclosed and evaluate 3 reasons that helped you come to that conclusion.

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