Enforcement of HNS Compliance Standards and Policies
HNS seeks to prevent accidental and intentional non-compliance with applicable laws, to detect such non-compliance if it occurs, to discipline those involved in non-compliant behavior, to remedy the effects of non-compliance, and to prevent repeat non-compliance.
When a material violation of applicable laws, regulations and/or compliance plan requirements has occurred, HNS is committed to taking appropriate steps to correct the problem, including appropriate disciplinary actions.
Appropriate disciplinary measures will be taken on a case-by-case basis but all contracted health care professionals will be subject to the same disciplinary action(s) for the commission of similar offenses.
A. Violations
When HNS concludes that a contracted health care professional has engaged in misconduct covered by the Compliance Program, the provider will be subject to appropriate disciplinary action, consistent with HNS sanctions for non-compliance.
HNS may:
- notify the provider of the violation within 10 days of such determination;
- refrain from the submission of claim(s) that HNS believes represents fraudulent or inappropriate billing;
- issue a verbal or written warning;
- require additional compliance training;
- require a corrective action plan (CAP);
- terminate the provider from the network;
- report the misconduct to the appropriate federal and state authorities; and/or
- prosecute the individual
B. Sanctions
HNS reserves the right to take action and apply sanctions based on the seriousness of the misconduct. In general, the following sanctions/disciplinary actions will be applied for misconduct relating to non-compliance.
1. Negligent Action by Contracted Health Care Professional
| First Offense | Oral or written warning and/or additional training |
| Second Offense | Written warning and/or corrective action plan and/or termination of participation in the HNS network |
| Third Offense | Written warning, corrective action plan, and/or termination of participation in the HNS network |
| Fourth Offense | Termination of participation in the HNS network |
2. Intentional Action by Contracted Health Care Professional
| First Offense | Written warning, corrective action plan, and/or termination of participation in the HNS network |
| Second Offense | Termination of participation in the HNS network |
C. Responsibility for Sanctions
Sanctions for Contracted Health Care Professionals
The review of the misconduct and the imposition of sanctions for contracted health care professionals will be the responsibility of HNS’ Compliance Officer and CEO.
D. Notifications of Sanctions/Disciplinary Actions
Notifications of sanctions/disciplinary actions will be communicated in writing to the party engaged in the misconduct and will include the misconduct and, as applicable, may include a summary of the results of the investigation.
Notifications of violations of laws may be reported to appropriate governmental agencies including, but not limited to, state licensing boards.
E. Records
Records related to non-compliance by contracted health care professionals will be retained electronically in HNS computer systems.