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Corporate ComplianceAnnual Update
2014
Corporate Compliance
• The federal Deficit Reduction Act (DRA) and subsequent Medicaid Integrity Program requires that all health care entities that annually bill or pay out $5 million or more in Medicaid establish a Corporate Compliance Program.
• A program is recommended for all health care entities.
Purpose of P&S Corporate Compliance
To have an effective compliance and ethics program:
– To exercise due diligence to prevent and detect wrong-doing
– To promote an organizational culture that encourages ethical conduct and a commitment to compliance with the law.
– To raise awareness
– To positively impact corporate reputation/culture
– To provide a “safe” mechanism(s) for reporting and seeking help
Objectives of P&S Corporate Compliance
To meet the objectives of the 7 elements of a corporate compliance program as
outlined by the (FSG) Federal Sentencing Guidelines:
1. Review Written Policies & Procedures
2. Select Compliance Officer & Committee
3. Training & Education
4. Effective Lines of Communication
5. Discipline & Background Checks
6. Auditing and Monitoring
7. Responding & Corrective Action
Written Policies & Procedures
• The focus of our program is on ethics and integrity in the workplace and
compliance with federal and state laws related to:
– Fraud
– False claims
– Theft or embezzlement
– Kickbacks
– Other violations
• The Compliance Program develop and implement policies, procedures, and best-
practices designed to ensure compliance with state & federal regulations and
programs.
– Accreditation Agency (DNV)
– Medicare/Medicaid requirements (CMS)
– HIPAA/HITECH requirements (OIG/OCR)
A working environment that encourages:
• Ethical and proper ways to do business
• Commitment
• Encourages problems to be reported
• Provides a process with constant monitoring
process which
– Deter
– Detect
– Correct
– Prevent Non-Compliant Behavior
P&S Code of Conduct
• P&S Surgical Hospital strives to provide the highest quality procedural care in a patient-focused environment. P&S Surgical Hospital is committed to our core values of:– Service– Respect– Compassionate Care– Friendliness– Stewardship
• The Code of Conduct provides standards by which all members of the organization will conduct themselves.
• Individual’s conduct must be in a manner that protects and promotes organizational-wide integrity and enhances P&S Surgical Hospital’s ability to achieve its objectives and mission.
• This applies to all employees, officers, administrators, board members, medical staff, vendors, contracted employees, consultants, students, and volunteers.
P&S’s Corporate Compliance Program Includes:
• Corporate Compliance Officer
– Report on a regular basis to the CEO, compliance committee, and when necessary to the governing body.
– Continue to design, implement, oversee, and monitor the compliance program.
• Corporate Compliance Committee
• Policy and procedures
• Corporate Compliance Plan
• Develop, coordinate, and participate in a multifaceted educational & training.
• Ensure that independent contractors and agents are aware of the organization’s compliance program
requirements.
• Assist with internal compliance review and monitoring activities.
• Anonymous hotline
Training & Education
• Communication process to report any compliance issues or concerns
• New Hire Orientation
• Code of Conduct Training – Annually
• 7 Elements of an Effective Compliance Program – Annually
• Conflict of Interest Statements – Annually
• Safe guarding PHI/ePHI
It is every employee’s responsibility to report suspected violations of the laws, regulations and policies, or other questionable conduct.
Effective Lines of Communication
Reporting Compliance Issues or Concerns:
1. Your manager
2. Executive Team Member
3. Director of Human ResourcesI. Chenire Craig- 998-7307
4. Compliance OfficerI. Dirk Rhodes – 998-6135
5. Compliance “Anonymous” Hotline - 1-866-570-2523
Effective Lines of Communication
• Dirk Rhodes, Corporate Compliance Officer – Phone: (318) - 998-6135– Contact via E-mail: [email protected]
• P&S Corporate “Hotline” ComplianceLine:
1-866-570-2523– 100% anonymous; Available 24 hours a day/ 7 days a
week– There will be no retaliation for reporting concerns in
good faith, but appropriate disciplinary action will be taken against those who commit misconduct.
• All reported allegations will have to be verified before any actions are taken.
Discipline / Background Checks
• Upon hire all employees undergo a background check/ drug screening.
• Monthly SanctionCheck is performed on all employees, medical staff, vendors, & contracts/business associates to show that P&S is compliant with CMS, federal & state regulations and various programs that we participate in.
• Annually employee(s) should receive a copy of the Sanction Policy that supports the Code of Conduct and outlines the disciplinary actions taken in the event of misconduct.
Auditing & Monitoring
• Unethical or inappropriate care of patients
• Lack of correct and sufficient documentation in admitting / discharging patients
• Medical Necessity • Billing for services or
supplies that were not provided
• Altering claims for higher payment
• 2 Annual (External) Billing/Coding Audits
• MCR inpatient one day stays
• Conflict of Interest /Inappropriate vendor relationships
• Inappropriate access and/or release of (PHI)
• Bribes or kickbacks• Business Associate
Agreements (BAA) • Physician Ownership
Disclosure
Responding & Corrective Action
• The Compliance Department reviews all allegations in a serious manner and takes the necessary steps to deter, detect, correct, & prevent any wrong-doing or misconduct.– All reported allegations will have to be verified before any actions are taken.
• All allegations, audits (internal & external), and monitoring is reported directly to the CEO/ Compliance Committee/Board as necessary.
• All allegations, audits (internal & external), and monitoring tools are responded back to in the allotted time frame per the institution guidelines.
• In regards to the P&S “Hotline” ComplianceLine– ≤ 72 hours to respond to any issue or concern (Severity I to III)
– May take longer considering certain factors and seeking P&S Legal Counsel for review
We want to provide a safe patient centered environment for Patients & Employees!!
Quick Facts
• All employees are held responsible and accountable for compliance and can be charged with fraud
• The corporate compliance committee investigates every complaint of noncompliance
• There will be no retaliation for reporting concerns in good faith, but appropriate disciplinary action will be taken against those who commit misconduct
• Law prohibits asking for or receiving anything of value to induce or reward referrals of Federal health care program business
Examples of Compliance Issues
• Never read another employee’s confidential records without permission
• Never use another person’s password to access confidential information
• Only discuss a patient’s condition with those involved in the patient’s care
• Never treat or act differently to someone because they identified a compliance or ethical issue
• Accepting gifts from vendors, providers, or third parties are prohibited as outlined in the conflict of interest policy at P&S. All gifts (>$25.00 per person per transaction) need prior administration approval before accepting.
• Only bill for visits, procedures and/or tests performed
• Always provide complete documentation for ALL services performed
Remember!
DO THE RIGHT THING:
• When you become aware of or observe something you believe to be improper, report it.
• Keep yourself trained and informed.
• No retaliation for reporting in good faith!
No Pointing Fingers!!
• End of Presentation