Training Plan Within 90 days after the Effective Date, Good Shepherd shall develop a written plan (Training Plan) that outlines the steps Good Shepherd will take to ensure that: (a) all Covered Persons receive adequate training regarding Good Shepherd’s CIA requirements and Compliance Program, including the Code of Conduct and (b) all Relevant Covered Persons receive adequate training regarding: (i) the Federal health care program requirements regarding eligibility for hospice services upon initial admission, recertification for continued stay, and for Continuous Care, Respite Care, and General Inpatient Care; (ii) the role of physicians in making eligibility determinations; (iii) the accurate coding and submission of claims; (iv) policies, procedures, and other requirements applicable to the documentation of medical records; (v) the personal obligation of each individual involved in the claims submission process to ensure that such claims are accurate; (vi) applicable reimbursement statutes, regulations, and program requirements and directives; (vii) the legal sanctions for violations of the Federal health care program requirements; and (viii) examples of proper and improper eligibility determinations, documentation, and claims submission practices. The Training Plan shall include information regarding the training topics, the categories of Covered Persons and Relevant Covered Persons required to attend each training session, the length of the training, the schedule for training, and the format of the training. Within 30 days of the OIG’s receipt of Good Shepherd’s Training Plan, OIG will notify Good Shepherd of any comments or objections to the Training Plan. Absent notification by the OIG that the Training Plan is unacceptable, Good Shepherd may implement its Training Plan. Good Shepherd shall furnish training to its Covered Persons and Relevant Covered Persons pursuant to the Training Plan during each Reporting Period.
