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OMIG Compliance Program

Prevents, detects and remedies inappropriate billing – protects whistleblowers – eight elements:

Written policies and procedures, including how to report

Designated compliance officer (best practice)

Training for employees, administrators and board members

Reporting line to compliance officer (including anonymous/confidential)

Discipline failing to report, permitting suspected non-compliance

Routine identification of risk areas – internal/external audit

Procedures to respond to, correct, and report compliance issues

Policy barring intimidation, retaliation or compliance activities

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