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Home Care Compliance Program Presentation (sound embed)
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Home Care Compliance Program Presentation (sound embed)

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I custom designed this PowerPoint template for our agency and I put together the presentation. Since Compliance can be a dull subject, the Compliance Manager wanted to me to create a “fun feel” …

I custom designed this PowerPoint template for our agency and I put together the presentation. Since Compliance can be a dull subject, the Compliance Manager wanted to me to create a “fun feel” presentation. You will notice that in the music clip on one of the slides and some of the graphics. Please view in slide show mode to get the best feel of the presentation and to hear the sound.

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Transcript

  • 1. Health and Home Care’s Compliance Program
    “Compliance is Everyone’s Responsibility”
    1
  • 2. What is Compliance?
    Compliance means following the rules. It means we understand and comply with all the laws, regulations, policies and procedures that apply to Health and Home Care and Health and Hospitals Corporation.
    2
  • 3. The Compliance Climate Continues to Change, even Since our Presentation last year!
    Congress and National Governors Conference Focus on Medicaid Fraud
    Ex-Governor Spitzer appoints JamesSheehan NY Medicaid Inspector General
    Governor Patterson appoints NYSMedicaid Inspector General Joseph Fisch
    Authorization to hire 75 additional auditorsthis year in NYOIG.
    First Annual NY OIG Work Plan issued by James Sheehan on April 19, 2008 with a focus on Fraud and Abuse of the 48 billion dollar Medicaid program.
    3
  • 4. How does Health and Home Care Structure its Compliance Program?
    Developed and expanded our comprehensive internal audit and Compliance Program to:
    Monitor and audit areas based on the 2008 OIG Work Plan and internal risk assessment areas of concern.
    Track and trend based on perceived and/or audited process issues
    Use results to formulate a plan of corrective action
    Re-audit to determine performance improvement
    Share comparative audit results quarterly with all department heads at the newly created “audit committee”
    Develop education programs to address audit findings and improve process and quality issues.
    4
  • 5. The Auditing Cycle
    (Re)Audit
    Findings
    Interventions
    Plan of Corrective Action
    5
  • 6. Who Oversees H&HC’s Compliance Program?
    Compliance Committee Members
    Executive Director
    Associate Executive Director/Compliance Officer - Committee Chairman
    Deputy Executive Director/Chief Nurse Executive
    Chief Financial Officer
    Director Patient Safety/ PI
    Associate Director Nursing/Compliance
    Privacy Officer
    Ad Hoc Participants
    6
  • 7. The Buck Stops Here…
    7
  • 8. New York City Health & Hospitals Corporation Compliance Oversight
    HHC Pres
    Corp Compliance Off
    Corp Compliance Committee
    Health & Home Care Executive Director
    Health & Home Care Compliance Officer
    Health & Home Care Compliance Committee
    Health & Home Care Employees
    8
  • 9. Office of the Inspector General (OIG) Major Home Care Risk Areas include:
    Billing for falsely credentialed HHA/PCA workers.
    Billing for services that could be performed by other willing and able caregivers
    Billing for items or services not actually rendered (All Payers)
    Billing for medically unnecessary services (All Payers)
    Submitting claims for equipment, medical supplies and services that are not reasonable and necessary
    Billing for Services provided to patients who are not confined to their residence (“homebound”)-as defined by the Medicare COPS
    Insufficient documentation to evidence that services were performed and/or to support reimbursement (All payers)
    Source: 2008 NY Medicaid OIG Work Plan
    9
  • 10. What Activities Comprise the Health and Home Care Compliance Program?
    Summary of Internal Audits
    • PPS Medicare Audit
    • 11. Outlier Audit
    • 12. Cost Report Audit
    • 13. Rehab Audit
    • 14. OASIS Integrity Audit
    • 15. Start of Care Documentation Audit
    • 16. HHA/PCA Attendance Audit and Training Certificate Review
    • 17. Vendor HIPAA Privacy Audits
    10
  • 18. What Internal Audit Activities Comprise the Compliance Program?
    Quarterly Mock Surveys
    HIPAA Privacy and Security Audits
    Professional and Paraprofessional Quality Integrity Audits
    Intake Audit
    Select Data External Coding Audit
    Select Data Invoice Review
    Post Billing Audits
    Managed Care denials followed-up for resolution
    11
  • 19. Professional and Paraprofessional Quality Integrity Audits
    A total of 217 patients (approx. 20% of census) were contacted during Q4 2007 to confirm Clinician Visits
    100% of visits were found to have been made.
    We expanded this Professional Services audit to include attendance checks of HHA/PCAs beginning April 1st, 2008
    Continuous review of HHA training certifications of new aides assigned to our cases and compare with the AG list of fraudulent training schools
    12
  • 20. What Activities Will Ensure Continued Compliance in the Future?
    Enhancing the visibility of the Compliance Program via Compliance Fairs, Compliance topic presentations at monthly borough meeting, posters with the theme that “Compliance is Everyone's Responsibility”, Compliance Newsletter and Compliance Tips
    Continue audits to address the annual NY OIG Work Plan and other risk areas identified by our internal risk assessment
    Expanding HIPAA Security audits in coordination with central IS
    Expanding clinical review functions
    Developing educational initiatives to address significant audit findings or areas where clinical, operational or financial improvements are indicated
    13