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noncompliant with FHCP Human Resources policies, the employee’s administrator shall be included to determine if a higher level of discipline is warranted. Compliance Plan 8 - 4 Revised December 12, 2018 F. Enforcement and Record Retention Responsibility For all substantiated allegations of misconduct, the employee’s Administrator shall be responsible for enforcing the prescribed discipline in accordance with this Policy. Additionally, the Compliance Officer shall ensure that all relevant documentation related to the substantiated allegation and the organization’s response to such act(s) is retained. Such documentation shall include, at a minimum, all evidence supporting the allegation, the justification for the classification of the offense, and a description of the discipline taken. Such documentation shall be retained for the term of the violator’s employment plus seven years. G. Downstream and Related Entities of FHCP FHCP shall take such corrective action with respect to any Downstream or Related Entity. Such corrective action shall take into consideration the recommendations of the Compliance Officer and the Compliance Committee, as well as the nature of any noncompliant activities and/or conduct, the severity of the action, the cooperation of the entity with respect to FHCP’s investigation, the actions of the entity in correcting the issue of noncompliance, and such other factors that FHCP, the Compliance Officer and Compliance Committee consider relevant. Such corrective action may include (i) imposition of a corrective action plan on the entity, which may include additional auditing and monitoring by FHCP; (ii) suspension or revocation of the entity’s performance of a particular activity or service under the contract with FHCP; and/or termination of the entity’s contract with FHCP. Reports to the MEDICs, CMS, OIG, OIR, and/or other federal or state agencies also may be made.
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