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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 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.
Write a 700- to 1,050-word paper discussing what steps need to be taken to explore the situation and conduct an internal investigation.
Complete the following in your paper:
- 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 to the 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.
- Write a preliminary opinion to executive leadership that evaluates whether this practice is compliant and ethical.
Cite properly cited in-text citations within the narrative of the paper and on the reference page reputable references in APA format to support your assignment (e.g., trade or industry publications, government or agency websites, scholarly works, or other sources of similar quality).
Format your citations according to APA guidelines.