CORPORATE CORPORATE COMPLIANCE COMPLIANCE

PROGRAMPROGRAM

HISTORY• Center for Medicare & Medicaid

(CMS) paid $20,000,000,000 in error !

• Improper payment due to:CODING & BILLING ERRORS FRAUD & ABUSE

• Enormous financial losses for government

PASSAGE OF HIPAA 1996Government $$$$ for resources to detect fraud & abuse

Criminal OffenseFines, Prison, Restitution, Sanctions,

Corporate Probation

OIG strongly recommends Corporate Compliance

Purpose of the Corporate Compliance

Program

• to maintain the highest level of professionalism and ethical standards in the conduct of its business

• to maintain the importance of our reputation for honesty, integrity and high ethical standards

Physicians and all TSC Employees

• are obligated to conduct themselves in a manner to ensure the maintenance of these standards

• are expected to adhere to ethical conduct and exhibit personal and professional integrity at all times

• to show respect for the rights and feelings of patients, co-workers and others

• refrain from any behavior that may be harmful or that may be viewed unfavorably by patients, co-workers and others

CORPORATE COMPLIANCE PROGRAM

CORPORATE COMPLIANCE PROGRAM

1. Written Policies and Procedures2. Quality Care and Services3. Reporting and Communication Policy4. Compliance with Laws and Regulations5. Medical Records6. Personnel7. Safe Work Environment8. Conflicts of Interests9. Coding, Billing and Documentation10.Protecting Property

CORPORATE COMPLIANCE: AN ONGOING PROCESS

1.Prevent

2. Detect/Correct3. Defend/Mitigate

RISK

REPORTING A VIOLATION

TSC Hotline 973-477-7217email

megoser@thestonecenter.orgAnyone can report a violation without

fear of ANY retaliation by:PhoneVerbalE-mailWritten