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Compliagent is a consulting firm with a singular mission – guiding our healthcare provider clients in designing, managing and maintaining compliance infrastructure. Serving over one-hundred healthcare facilities, providers, and business associates, we view compliance as an opportunity to partner with our healthcare provider clients to mitigate regulatory risk proactively and to build stronger organizations in a cost-effective way, ultimately leading to profitability increases and cost savings.
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Nick Merkin11845 W Olympic Blvd., Suite 1250
Los Angeles, CA 90064
310.996.8950
www.compliagent.com
Seven Elements of a
Compliance Program
WRITTEN COMPLIANCE POLICIES AND PROCEDURES
DESIGNATED COMPLIANCE
PROFESSIONALS
EFFECTIVE TRAINING OF ALL
STAFF
EFFECTIVE COMMUNICATION
PREVENTATIVE AUDITING AND MONITORING
ENFORCEMENT OF STANDARDS
PROMPT RESPONSE TO POTENTIAL COMPLIANCE VIOLATIONS
The Structure of our Programming...
Program
Assessment
and
Development
of a Tailored
Compliance
Plan…
Program Assessment and Development
of a Tailored Compliance Plan
Program Assessment
• Conduct initial assessment of
compliance programming already in
place.
• Identify areas for improvement and
risk concern.
• Presentation of findings through
confidential memoranda and
discussions with governing board and
senior management.
Compliance Plan
• Development of strategic compliance
plan narrowly-tailored to specific
client’s business and regulatory needs.
• Continuous monitoring and updating
of compliance plan to reflect
emerging risk areas and regulatory
developments.
Education and
Communication
of Culture of
Compliance…
Quarterly Compliance Survey
• Issue Compliance Survey to key Facility employees to encourage reporting of actual or potential compliance violations
• Investigation by Compliagent of any reported issues
• Outcome of investigations are reported to the Facility’s Governing Board and monitored by Compliagent for effective resolution as indicated
Update to Compliance Plan
• Annual review of the Compliance Plan (See Exhibit A)• Distribute Compliance Plan to facilities on an annual basis• All Facility employees receive a copy of the Compliance Plan
Participation in Policy Committee
• Assist with the development of a monthly policy review agenda• Provide regulatory and clinical guidance for policy development
Monthly Facility Updates
• Monthly newsletter and additional guidance statements concerning regulatory issues as warranted
• Quarterly distribution of Dashboard reporting Facility specific compliance metrics (See Exhibit B)
• Issue policy updates from Policy Committee
Education and
Communication of Standards
Ongoing Compliance Support
and Guidance
• Each Facility is assigned a
designated consultant to provide
ongoing support with the
maintenance of the Compliance
Program
• Compliagent consultants are
available to the facilities to
provide guidance with regard to
operational and clinical
regulatory issues as needed
Quarterly Training
• Mandatory Annual Training: Compliance
Program and HIPAA
• Additional training topics are selected by
Compliagent based upon client request,
observed need, and regulatory
enforcement priorities (See Exhibit C)
• Trainings are conducted both on-site
and via webinar
• Compliagent provides training materials
to Director of Staff Development for
mandatory in-services to all staff
Education and Communication
of Standards (Continued)
Risk Management…
Risk Management
Compliance Complaint
Investigation
• Develop investigation plan in coordination with Facility Compliance Officer
• Investigation may include interviews of residents and/or employees, resident specific record review, or audit of multiple records
• Investigational findings and recommendations are communicated to the Compliance Officer, Administrator and Governing Board (See Exhibit D)
Hosting of Compliance Hotline
• Hotline posters provided to each Facility• Compliance Hotline is a voicemail box that permits
reporting 24/7 and allows callers to remain anonymous• Hotline calls are reported to the Compliance Officer
and Administrator, unless a conflict of interest exists
Risk Assessment
• The Risk Assessment is revised annually base don regulatory enforcement priorities
• Facilities complete the Risk Assessment on an annual basis
• The Risk assessment using scoring based upon the response to determine the prioritization of risk management
Risk Management (Continued)
Compliance Audits
• Client selects the audit area for the
Facility based on the information
provided in the Risk Assessment
• Audits include both operational and
clinical topics (See Exhibit C)
• Audit findings and recommendations are
communicated to the Compliance
Officer, Administrator and Governing
Board
Exclusion Screening
• Monthly exclusion screening performed
for all facility employees
• Any negative results are communicated
to Compliagent Consultants and the
facilities
• Compliagent consultants coordinate
with the Facility’s administrator to
address and resolve identified exclusions
Monitoring and Reporting…
Monitoring and Reporting
Monitoring of Compliance Action Plan
• Facility develops an action plan to
address risk area identified in the OIG’s
annual work plan
• Any corrective actions resulting from
hotline complaints or audits are also
added to the action plan
• Compliagent reviews the Facility’s action
plan no less than quarterly to ensure
effectiveness of the corrective actions
Governing Board Reports
• Compliagent will report all Compliance
Program activity from the preceding
quarter and provide updates on an
ongoing activities
• The Administrator reports on topics such
as survey results, compliant surveys, QAPI
activity, etc.
Maintenance
and
Validation…
Maintenance and Validation
Annual Compliance Program
Assessment
• Compliagent conducts an annual assessment to determine how effectively the Facility has implemented each of the OIG’s identified 7 elements of compliance
• Results are communicated to the Compliance Officer and Governing Board
Quarterly Compliance Program Dashboard
• Compliagent issues a Facility specific dashboard quarterly to capture the Facility’s progress and areas for improvement
• The information captured on the dashboard will vary but may include Risk Assessment scoring, Compliance Program Assessment scoring, hotline call volume, and quality measures
Annual Risk Profile Evaluation
Assessment
• Compliagent has developed a tool for the categorization of risk to identify priority facilities
• The data used includes survey deficiencies, quality measure data, staff turnover, star rating, etc.
• Compliagent updates the used to calculate the risk profile on an annual basis
The Business
Benefits of
Independent
Compliance
Programming …
Access to Multiple Professionals With Varied
Specialties Through a Single Point of Contact…
Single Point of Contact
We bring to bear a higher level of
professional firepower to a compliance
matter at a lower cost.
Access a network of qualified compliance
professionals with different specializations
through a “one-stop shop” approach…
Even Larger Healthcare Organizations Need Help• May only have a handful of experienced
compliance professionals with a narrow
range of expertise on staff.
Evaluating of Resources• Only enough room and resources for so
many senior compliance personnel within
one entity.
Lower Upfront Investment…
Lower Upfront Cost
Even for organizations that are committed to building
out a more extensive internal compliance
department, it usually makes financial sense to begin
with a combination of insourced and outsourced
expertise.
The initial investment in hiring qualified and
experienced healthcare compliance
professionals is high…
Building Compliance Infrastructure On Your Own is
Expensive• Hiring even a single compliance specialist and
assistant may cost a healthcare organization
hundreds of thousands of dollars a year.
Outsourcing Saves You Money• Upfront expenditures involved in outsourcing an
entity’s compliance function are much lower and
involves a much smaller commitment to a scope of
work that is narrowly defined and leanly priced in a
detailed retention agreement.
Quicker
Adaptation
to Regulatory
Changes…
Regulatory Adaptation
We a unique, multi-faceted perspective, gained from
advising a variety of organizations, to develop “best
practices” with an eye towards your business goals.
Regulation Requirements are Going
to Get Worse…
Internal Change is Hard
• Implementing organizational change internally
can be cumbersome and a drain on
resources.
Outsourcing Makes it Easier
• We focus specifically on the nuances of legal
change and interpretation, are better suited
than an internal corporate compliance
department to monitor and react swiftly to
changing laws and regulations.
More Flexible
Use of
Compliance
Resources…
Compliance ResourcesCompliance 101
We have specialists in all these areas, so we
can more nimbly address your evolving
compliance concerns.
We give you the ability to pick and choose from a
menu of compliance options at any given time…
Specialized Resourcing
• We are able to tailor our resources based on
an organization’s most recent compliance
plan or risk assessment
• Ex. HIPAA Training or Employee Screening
Flexibility
• We can follow new, strict budgets that will
address any more pressing compliance needs
as the organization grows
• Resources are not locked-in to any
particular need
Third-Party Objectivity…
We’ve earned more credibility and success in
reaching agreements and compromises with the
government on behalf of their own clients.
Third-Party Objectivity
Third-Party Objectivity is Two-Fold…
Internal
• Difficult for employees to be completely
objective about the strengths and, especially,
the weaknesses in the organization
• Fear of reprisal and fear of judgment is a high
concern for employees
External
• Third-party conclusions may be viewed as
more independent
• Outsourced compliance specialist findings
carry greater weight
We Guide
Providers and
Help Them
Develop Self-
Perpetuating,
Scalable
Infrastructure…
Improving the Bottom Line…
Nick Merkin11845 W Olympic Blvd., Suite 1250
Los Angeles, CA 90064
310.996.8950
www.compliagent.com
Thank You.
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