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section15 - Implementing a Medicare Compliance Program...

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Implementing a Medicare Implementing a Medicare Compliance Program Compliance Program
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Implementation of Medicare Implementation of Medicare Compliance Program Compliance Program Rules & procedures to reduce chance of wrongdoing High level manager to oversee the program Procedures in place to preclude delegating responsibilities to person who has previously engaged in known illegal activities
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Implementation of Medicare Implementation of Medicare Compliance Program Compliance Program Effective employee communication regarding their obligations Monitoring, audit systems, & private reporting mechanisms to achieve compliance Consistent enforcement & discipline
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Implementation of Medicare Implementation of Medicare Compliance Program Compliance Program Appropriate, consistent, & documented responses to compliance violations Documented sanctions for failure to detect violations Documented program revisions to preclude future violations
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ERISA ERISA Employee Retirement Income Security Act
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Purpose of ERISA Purpose of ERISA To protect participant & beneficiary rights & interests in benefit plans
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Responsible Parties in Responsible Parties in Managing a Retirement Managing a Retirement Program Program Plan Administrator Multiple duties Trustee Makes investment decisions in terms of company to utilize
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Responsible Parties in Responsible Parties in Managing a Retirement Managing a Retirement Program Program Investment Manager Makes investment decisions for plan assets assigned to it Board or Plan Sponsor The employer organization has multiple responsibilities
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Definition of Retirement Plan Definition of Retirement Plan Assets Assets Employer contributions Employee contributions
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