MEDINOVA DIAGNOSTIC CENTRE Document #:

LABORATORY MDC/LAB/I-002
CORPORATE COMPLIANCE PLAN
Revision #:2 Page 1 of 3

The Laboratory Department at Medinova Diagnostic Centre (MDC) strives to maintain a

reputation for conducting all fiscal and operational aspects of the centre in accordance
with the highest level of business and community ethics. As a healthcare provider,
MDC is committed to operating under the highest ethical and moral standards, and
ensures that our facility, in all of its activities, complies with applicable national laws,
regulations and guidelines.

This corporate compliance plan is designed to detect and prevent accidental and
intentional noncompliance with applicable laws, throughout the organization. The plan
contains organizational conduct requirements that are intended to address pertinent
compliance issue and the overall scope of conduct, however are not to be considered
all inclusive.

CORPORATE COMPLIANCE STANDARDS AND PERSONNEL

CONDUCT:

 The leaders of this organization have made the commitment to provide a

corporate culture promoting high moral and ethical business practices.
Personnel of the organization are expected to comply with all applicable laws as
well as the policies and procedures of this facility.

 Fraud and Abuse:

 MDC employees shall not knowingly and willfully make or cause to be
made, any false statement or representation of material fact in any claim
or application for benefits under any local healthcare program or
healthcare benefit program. MDC personnel shall not, with knowledge
and fraudulent intent, retain services which have not been properly paid.
Prohibited conduct includes, but may not be limited to:

 Billing for services not actually rendered;

 Misrepresenting services which were rendered;

 Making false statements to governmental agencies about the

organization’s compliance with any rules;

 Falsely certifying that services were medically necessary;

 Charging rates in excess of applicable facility established rates;

CONTROLLED DOCUMENT
Issue Date: Feb. 2008 Related forms: Yes [ ] No [ ]
Revision Date: Feb 2010 Next Review Date: Feb. 2012
Revision Date: March 2013 Next Review Date: March 2015
 MEDINOVA DIAGNOSTIC CENTRE Document #:
LABORATORY MDC/LAB/I-002
CORPORATE COMPLIANCE PLAN
Revision #:2 Page 2 of 3

 Present a higher level of service or procedure to insurance

companies, thus resulting in an increase in reimbursement rate;

 Failure to refund overpayments made by a client

 Ethical Patient Referrals:

 MDC personnel who have an ownership or compensated

relationship in outside facility, shall not refer a patient in need of
designated health services for receiving care that is provided by
MDC

 Healthcare Fraud:

 MDC personnel shall not knowingly or willfully execute, or attempt

to execute, a scheme or tactic to:

 Defraud any health insurance program, or

 False Statement and False Claims:

 Civil False Claims:

 MDC personnel shall not perform or conduct any of the following

acts:

 Knowingly file a false or fraudulent claim for payments to a

healthcare insurance program,

 Examples of false or fraudulent claims include, but are not limited

to:

 Double billing

 Submitting or processing claims for items or services not

provided

 Submitting or processing claims for items or services not

medically necessary
CONTROLLED DOCUMENT
Issue Date: Feb. 2008 Related forms: Yes [ ] No [ ]
Revision Date: Feb 2010 Next Review Date: Feb. 2012
Revision Date: March 2013 Next Review Date: March 2015
 MEDINOVA DIAGNOSTIC CENTRE Document #:
LABORATORY MDC/LAB/I-002
CORPORATE COMPLIANCE PLAN
Revision #:2 Page 3 of 3

 Billing for non-covered services

 Clinical Laboratory Compliance:

 The Clinical Laboratory operated under the license of MDC shall operate
in accordance with the standards set forth by the Department of Health
and Medical Service (DOHMS).

APPROVAL
Name Signature Date
Prepared by: Nazira Begum, Assistant manager

Approved By: Sunita Vaidya, Laboratory Director

CONTROLLED DOCUMENT
Issue Date: Feb. 2008 Related forms: Yes [ ] No [ ]
Revision Date: Feb 2010 Next Review Date: Feb. 2012
Revision Date: March 2013 Next Review Date: March 2015