I .
Detection and Prevention A . Internal FWA
Hometown Health has adopted FWA detection , prevention and non-retaliation procedures . Below summarizes Hometown Health ’ s controls .
Compliance Program
Hometown Health ’ s compliance program (“ Program ”) establishes a proactive , robust and ongoing detection and prevention program for FWA to comply with federal , state and other applicable regulations . All staff and entities are required to report any suspicion of FWA to their supervisor , the Compliance Manager , anonymous on the Compliance Hotline ( at 1-800-611-5097 ) and / or online , without retaliation . The Compliance Department will provide oversight and assistance with FWA regulatory reports to state and / or federal agencies , as needed .
The Program prohibits retaliation against those who , in good faith , reports a concern or who participates in the investigation of compliance related issues . The Compliance Program provides that compliance concerns will be investigated rigorously and resolved promptly . Investigations regarding Compliance Program violations are conducted by Hometown Health ’ s Compliance Department , Corporate Compliance / General Counsel , Internal Audit , or Human Resources depending upon the nature of the violation . Compliance and fraud and abuse training is provided to all new employees , and to existing employees no less than annually .
B . External Fraud 1 . Prevention and Detection
Hometown Health strives to detect and prevent FWA by receiving referrals from variety of sources and through the use of its detection software . Hometown Health utilizes a variety of methods to seek out fraud and abuse as identified below :
a ) Fraud Detection Software
Data will be routinely analyzed by Hometown Health ’ s departments : Decision Support , Clinical , Pharmacy and Reimbursement Services based upon issues
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