Corporate compliance annual update


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Corporate compliance annual update

  1. 1. Corporate Compliance Annual Update 2014
  2. 2. 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.
  3. 3. 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
  4. 4. 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
  5. 5. 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)
  6. 6. 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
  7. 7. 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.
  8. 8. 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.
  9. 9. 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.
  10. 10. 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
  11. 11. Effective Lines of Communication • Dirk Rhodes, Corporate Compliance Officer – Phone: (318) - 998-6135 – Contact via E-mail: • 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.
  12. 12. 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.
  13. 13. 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
  14. 14. 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!!
  15. 15. 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
  16. 16. 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
  17. 17. 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!!
  18. 18. • End of Presentation