Granger Genetics is committed to maintain compliance with applicable legal and ethical standards. The success of Granger Genetics compliance efforts depends on the dedication of each employee or other agent to work with the company to implement and adhere to the Compliance Program.
Employees and others have the freedom to communicate compliance-related questions or concerns in person, by telephone, or through e-mail or other written correspondence. Any of these methods may be used to communicate with the Director of Compliance at any time, whether to report a suspected violation or to request guidance on a compliance issue.
No employee or other agent, contract worker, customer, vendor, or other person who does business with this organization is exempt from the requirements contained in the compliance policy which includes but is not limited to:
- Achieving a culture of uncompromising integrity which is characterized by strict adherence to all federal, state, and local laws and regulations applicable to Granger Genetics’s business operations.
- Full compliance with laws prohibiting fraud and abuse, (the federal False Claims Act, federal Anti-Kickback Statute, the Stark Law, and similar state laws).
- Employees, directors, officers and other agents such as contracted representatives must not present or cause to be presented any false or fraudulent claims for payment.
- Granger Genetics will submit claims for reimbursement to state and federal health care programs only if the ordering physician has signed for the test request indicating medically necessary services.
- Granger Genetics expects all employees, directors, and officers and other agents to conduct business on its behalf in strict adherence with the laws and ethical standards applicable to the company’s business practices, without regard to personal considerations.
- Employees, directors, and officers and other agents should never solicit gifts or any other personal benefit or favor of any kind from any individual or company doing business with Granger Genetics in exchange for, or as a reward or inducement for, business or for recommending or arranging for business to be referred to Granger Genetics.
- All interactions with health care professionals and their staff on behalf of the Company must be professional exchanges meant to provide education about Granger Genetics’s test offerings and the benefits they offer to professionals and patients.
- Granger Genetics does not employ or contract with individuals who or entities that are prohibited from doing business with any state or federal agency. OIG is checked on a routine basis for exclusions.
- Employees, directors, and officers and other agents must comply with state and federal laws and regulations, including the Health Insurance Portability and Accountability Act (known as “HIPAA”), governing the privacy and security of patient information.
- Employees, directors, and officers and other agents are prohibited from offering any gift or other item of value to a health care professional.
- Granger Genetics does not offer professional courtesy testing to HCPs, family members of HCPs or employees of HCPs. Testing services provided to HCPs, family members of HCPs or employees of HCPs must be billed to the patient or to the patient’s insurer in accordance with normal pricing and billing practices.
- Employees, directors, and officers and other agents are prohibited from offering processing and handling fees to a health care professional for processing of paperwork, sample preparation, sample mailing and/or other trivial task associated with submission of a sample