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Corporate compliance annual update
 

Corporate compliance annual update

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    Corporate compliance annual update Corporate compliance annual update Presentation Transcript

    • Corporate Compliance Annual 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.
    • 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 Resources I. Chenire Craig- 998-7307 4. Compliance Officer I. 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: DirkRhodes@pssurgery.com • 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