HI545 Unit 3 Compliance Policy Draft Example

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This HI545 Unit 3 compliance policy draft extends exclusion screening to agency, travel and contracted staff at a composite health system whose old rule covered employees only. Purdue Global HI 545 asks MS in Health Informatics students to write or revise a compliance policy, and the sample begins from a measured gap: 63 people placed by staffing agencies, none screened by the system itself. The revised policy checks every person and entity against the federal and state exclusion lists before start and monthly after. An agency's own screening counts only as a supplement. Possible matches are verified within two business days, internal audit samples thirty workers a quarter to test the screening itself, and a missed check triggers rescreening, contract action or a report to the board.

CourseHI545 Health Care Compliance
UnitUnit 3
Paper typeCompliance policy draft
LengthAbout 860 words, 6 pages double-spaced
FormatAPA 7 student paper
SchoolPurdue University Global
ProgramMS in Health Informatics
UpdatedOctober 2026

Free sample paper for HI545 Unit 3

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Everyone Who Touches a Claim: A Unit 3 Compliance Policy Draft Extending Exclusion Screening to Agency and Contracted Staff

[Student Name]

Purdue University Global

HI545: Health Care Compliance

Unit 3 Compliance Policy Draft

[Instructor Name]

[Date]

Esterline Health, its departments and every count are composite; the statutes and guidance cited are real.

What this part is doingOpening with the gap the old policy left, in one sentence, tells the grader why the draft exists before any rule appears.
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Policy Header

Title: Screening of Individuals and Entities Against Government Exclusion Lists. Policy number: COMP-114, revision 2. Owner: Chief Compliance Officer. Approved by: Compliance Committee. Applies to: Esterline Health hospitals, clinics and the acquired pulmonology and sleep medicine practice. Effective: on approval. Replaces: COMP-114 revision 1, which applied to employees only.

Purpose

Medicare and Medicaid refuse payment for anything an excluded person or company provides, orders or prescribes, and an organization that puts an excluded person to work on that care risks civil money penalties of its own (42 U.S.C. § 1320a-7a, 2024). Inspector general guidance urges providers to screen employees, contractors and agents before hiring or contracting and periodically after (Office of Inspector General [OIG], 2013). This policy sets out how Esterline Health does that, including for people it does not employ.

Why Revision 2 Was Needed

The first revision screened new hires through human resources. It did not reach travel and agency staff, locum physicians, independent contractors, students on rotation or vendors who supply clinical services. A count during the acquisition review found 63 people working in Esterline facilities through staffing agencies on a single day, including respiratory therapists, sleep technologists and a coding contractor, none screened by Esterline. Each staffing contract said the agency would screen, but nobody at Esterline had ever checked that it did. A staffing agency's promise to screen is a contract term, not evidence, and the penalty for paying an excluded worker falls on the provider that billed for the work.

What this part is doingCounting the unscreened workers before writing the fix shows the grader that the policy answers a measured gap rather than a general worry.
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Scope

This policy covers every individual and entity who furnishes, orders, prescribes or bills for items or services paid in whole or part by a federal health care program, or who performs administrative or management work related to such services. That includes employees; medical staff and advanced practice providers; agency, travel and locum staff; independent contractors; students and trainees with patient contact; volunteers who handle records; and vendors and their personnel who furnish clinical, billing or coding services.

Lists Checked

1. The OIG List of Excluded Individuals and Entities.

2. The System for Award Management exclusion records.

3. The Medicaid exclusion or termination list of each state where Esterline bills Medicaid.

4. Licensure databases for any license or certification the role requires, for status and discipline.

Procedure

1. Before start. No person or entity in scope may begin work until screened against all lists by the compliance office or its screening vendor. Human resources, medical staff services and supply chain submit names, dates of birth and license numbers through the screening request form.

2. Agency and contracted staff. The staffing agency's own screening is accepted as a supplement only. The agency must send a roster of every placed worker before the start date, and the compliance office screens that roster itself.

3. Monthly. All active individuals and entities are rescreened each month after the federal list update. Agencies send an updated roster within five business days of each month's start; any worker not on the roster is presumed active until the agency confirms otherwise.

4. Possible match. A possible match is verified within two business days using date of birth, license and, if needed, the list's verification process. The worker is removed from any duty involving federal program services pending verification.

5. Confirmed match. The compliance officer notifies legal counsel the same day. The person or entity is removed from all covered work. Counsel decides on refund and disclosure, and the matter is handled under the investigation procedure.

6. Records. Each screening is logged with date, lists checked, result and the person who ran it, and kept for at least six years.

What this part is doingRequiring Esterline to screen the agency's roster itself, instead of relying on the agency, is the single change that closes the gap the review found.
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Oversight of the Screening Itself

The internal audit function tests the screening process quarterly. Each quarter it draws a random sample of 30 active workers, at least ten of them agency or contracted staff, and confirms that a log entry exists for the current month and for the start date. The compliance committee receives the result.

What a Missed Check Triggers

1. Any sampled worker without a current monthly screen is screened the same day.

2. If two or more of the 30 lack a current screen, the full population of that department or agency is rescreened within five business days.

3. Any agency that fails to send its monthly roster twice in a year is reported to supply chain for contract action.

4. A missed check that conceals a confirmed match is reported to the board's audit committee at its next meeting.

Training and Communication

Managers who approve agency staff receive a one-page explanation of this policy. Staffing contracts are amended at renewal to require the monthly roster and cooperation with Esterline's screening. The general guidance treats screening as part of the broader auditing and monitoring element of a compliance program (OIG, 2023), and this policy will be reviewed annually with the rest of the program.

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References

Office of Inspector General. (2013). Updated special advisory bulletin on the effect of exclusion from participation in federal health care programs. U.S. Department of Health and Human Services.

Office of Inspector General. (2023). General compliance program guidance. U.S. Department of Health and Human Services.

42 U.S.C. § 1320a-7a (2024). https://www.law.cornell.edu/uscode/text/42/1320a-7a

HI545 Unit 3 instructions, in plain terms

The third unit usually asks you to draft a compliance policy that addresses a risk identified in the case. Expect a policy header, purpose, scope, definitions or lists used, a numbered procedure, responsibilities, monitoring and a review date. Many instructors want the policy to state who checks that it is followed, not just what staff must do. Use the plain voice of a policy manual: short numbered steps, each tied to a named role. Cite the statute or guidance that makes the policy necessary in the purpose section. Where the prompt supplies an organizational template, use its headings. Three to five pages is common. A brief note on why the revision was needed, if you are revising an existing policy, helps graders see the gap the draft closes. Check that every step has an owner and a time limit.

Inside the HI545 Unit 3 example

The header gives a policy number, owner, approving body and what the revision replaces. Purpose explains the payment bar and the penalty exposure in two sentences with citations. A short section on why revision 2 was needed reports the count of unscreened agency workers, and the highlighted sentence explains that an agency's promise to screen is a contract term, not evidence. Scope lists every category of worker and vendor in plain terms. Four lists to be checked follow. A six-step procedure covers screening before start, the agency roster rule, monthly rescreening, verification, confirmed matches and records. A separate section makes internal audit test the screening itself each quarter, and another lists what a missed check sets in motion. Training and contract changes close the draft. Margin notes mark the measured gap and the roster rule.

Where the points sit in the HI545 Unit 3 rubric

Policy drafts tend to be graded on completeness, clarity and enforceability. A large share of points rests on whether the procedure can be followed as written, with owners, time limits and records. Scope earns credit when it covers everyone the risk touches; here that means contracted and agency staff as well as employees. A row for legal and regulatory basis rewards accurate citation in the purpose section. Monitoring and accountability, how the organization knows the policy works, often separates strong drafts from adequate ones. Format, consistency with the template and APA citation complete the rubric. Students lose points by writing aspirations, such as staff will be screened as appropriate, by leaving out who audits compliance, or by relying on contract language as if it guaranteed performance.

Common HI545 Unit 3 mistakes, and how to avoid them

Policies on this topic often come back with a scope that quietly excludes the people most likely to slip through: agency staff, students and vendors. Another common gap is screening only at hire, which misses exclusions imposed later. Many drafts state what to do with a possible match but not how fast, or remove the person only after confirmation. Monitoring is frequently missing, so nothing would show whether the screening happens. Policies sometimes cite no authority at all. If your case names a different risk or organization, gather the case, any existing policy you are revising and the template your section uses, and a policy can be drafted to fit your organization with owners and audit steps written in.

Get an HI545 Unit 3 example written to your instructions

Exclusion screening is one choice; conflicts of interest, gifts, record retention and billing holds also turn up as Unit 3 topics. Send the prompt, the rubric and whatever policy format the course provides; the draft will carry its own monitoring clause in that format. There is no fee for a first custom sample; turnaround runs 24-48h. The paper above is an original model document written by our desk, not a submitted student paper and not an official Purdue University Global document.

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HI545 Unit 3 questions, answered

Why screen monthly instead of at hire only?

Because exclusions keep being imposed after people are hired. OIG updates its exclusion database monthly, and federal programs generally will not pay for items or services furnished, ordered or prescribed by an excluded person. A single screen at hire says nothing about the months that follow, so the sample fixes a monthly interval and audits that it actually ran.

Does contract language with a staffing agency solve the problem?

It helps allocate responsibility but does not remove the system's own exposure. The organization that bills for the service is the one facing penalties if an excluded individual furnished it. The sample therefore requires agencies to screen and attest, then screens agency staff directly anyway, recording both checks so the file shows who looked and when.

What policy template should the draft use?

Whatever the section supplies. Many prompts provide an organizational template with fixed headings; others leave the format open. The sample follows a common structure of purpose, scope, definitions, statement, procedure, monitoring, enforcement and approval. If your instructor issued a different layout, include it with the request and the draft follows that one instead.

Where can I find a free HI545 Unit 3 sample paper?

The full Unit 3 policy is posted here, extending exclusion screening to agency and contracted staff with monthly checks and a quarterly audit.

Why screen agency staff if the agency already does?

The penalty falls on the organization that billed for the work, and in this case the agency had checked only a state list.