The document provides an overview of the purpose and objectives of P&S Surgical Hospital's corporate compliance program. It details the 7 elements of an effective compliance program as outlined by the Federal Sentencing Guidelines, including written policies and procedures, a compliance officer and committee, training and education, effective communication lines, discipline procedures, auditing and monitoring, and responding to and correcting issues. It provides examples of compliance issues and a case study for employees to review."
Onsite Care: Can This Strategy Change Your Health Care Game?HNI Risk Services
Onsite care programs are rapidly gaining popularity, both as a mechanism to control costs and to increase the value of benefits offered to employees. Employees love onsite clinics for the convenient access to care they provide — and employers are eager to realize cost savings, enhance worker productivity, and tout the value of the offering to attract and retain talent.
How to succeed at cash-based telepsychiatry: 10 Worst Fears That Never Came TrueVSee
Is starting a cash-based private practice your best way to gain practice freedom and be empowered to treat patients without getting second-guessed by middlemen?
Whether pharmacist or physician, switching over can be scary. And is it really worth the trouble? Join our guest Chris O’Brien, PharmD as we discuss why he decided to go completely virtual and cash-based. Learn how he has built a thriving private practice and how he overcame his worst fears about doing telepsychiatry. Get practical tips on finding the right tools and technology, navigating telehealth regulations, recruiting, and marketing to potential clients.
Get all our telehealth podcast @ vsee.com/webinars
So what is Telehealth? It’s simple: you can receive medical care from U.S board-certified doctors anytime, anywhere. 24/7/365. Simply stated, our Telehealth service is a more convenient, more cost effective way for you to resolve many of your medical issues, including having prescriptions filled. No need for an appointment. No need to drive to a doctor’s office.
Onsite Care: Can This Strategy Change Your Health Care Game?HNI Risk Services
Onsite care programs are rapidly gaining popularity, both as a mechanism to control costs and to increase the value of benefits offered to employees. Employees love onsite clinics for the convenient access to care they provide — and employers are eager to realize cost savings, enhance worker productivity, and tout the value of the offering to attract and retain talent.
How to succeed at cash-based telepsychiatry: 10 Worst Fears That Never Came TrueVSee
Is starting a cash-based private practice your best way to gain practice freedom and be empowered to treat patients without getting second-guessed by middlemen?
Whether pharmacist or physician, switching over can be scary. And is it really worth the trouble? Join our guest Chris O’Brien, PharmD as we discuss why he decided to go completely virtual and cash-based. Learn how he has built a thriving private practice and how he overcame his worst fears about doing telepsychiatry. Get practical tips on finding the right tools and technology, navigating telehealth regulations, recruiting, and marketing to potential clients.
Get all our telehealth podcast @ vsee.com/webinars
So what is Telehealth? It’s simple: you can receive medical care from U.S board-certified doctors anytime, anywhere. 24/7/365. Simply stated, our Telehealth service is a more convenient, more cost effective way for you to resolve many of your medical issues, including having prescriptions filled. No need for an appointment. No need to drive to a doctor’s office.
Health Employment - Short term sickness absence and dealing with a pandemic w...Browne Jacobson LLP
This session provides you with top tips and issues to consider when dealing with short term sickness absence Gemma Steele also looks at what you can do during a pandemic.
Join HRG coding expert Vanessa Brumfield as she reviews the coding & documentation requirements for behavioral health. We will Review CPT and documentation guidelines for outpatient behavioral health encounters. We will discuss common behavioral health diagnoses & CMS telemedicine reporting requirements for behavioral health.
Results of a survey of 1,112 UK men by Opinion Leader on behalf of the Men's Health Forum to investigate men’s views of healthcare services and drivers and barriers to use, with a particular focus on those drivers and barriers that are associated with employment.
If inspection is the enemy of improvement, someone's not doing it right.Rami Okasha
What is the relationship between scrutiny and improvement? How can modern forms of scrutiny which focus on outcomes support improvement and innovation in social care? This paper describes some emergent approaches and results in Scotland being pioneered by the Care Inspectorate.
Telemedicine is one of the top 10 ways to survive rising health care costs. Lower costs, minimal risk and keeping you ahead of the competition are just a few of the benefits of telehealth. Contact us to learn about the advantages of using Benefit Intelligence as your Telemedicine Administrator.
PeoplePro Strategies to Promote Employee Health and Wellbeinglil1166
A healthy workforce is strongly aligned with business success. A healthy workforce can increase productivity, reduce absenteeism, generate higher retention and better overall engagement.
Download our webinar "Strategies to Promote Employee Health and Wellbeing" and discover insights that can be used by employers of all sizes to begin to increase health and safety of employees while reducing cost. You will find tips to implement right away and insights to share with senior leadership.
Health Employment - Short term sickness absence and dealing with a pandemic w...Browne Jacobson LLP
This session provides you with top tips and issues to consider when dealing with short term sickness absence Gemma Steele also looks at what you can do during a pandemic.
Join HRG coding expert Vanessa Brumfield as she reviews the coding & documentation requirements for behavioral health. We will Review CPT and documentation guidelines for outpatient behavioral health encounters. We will discuss common behavioral health diagnoses & CMS telemedicine reporting requirements for behavioral health.
Results of a survey of 1,112 UK men by Opinion Leader on behalf of the Men's Health Forum to investigate men’s views of healthcare services and drivers and barriers to use, with a particular focus on those drivers and barriers that are associated with employment.
If inspection is the enemy of improvement, someone's not doing it right.Rami Okasha
What is the relationship between scrutiny and improvement? How can modern forms of scrutiny which focus on outcomes support improvement and innovation in social care? This paper describes some emergent approaches and results in Scotland being pioneered by the Care Inspectorate.
Telemedicine is one of the top 10 ways to survive rising health care costs. Lower costs, minimal risk and keeping you ahead of the competition are just a few of the benefits of telehealth. Contact us to learn about the advantages of using Benefit Intelligence as your Telemedicine Administrator.
PeoplePro Strategies to Promote Employee Health and Wellbeinglil1166
A healthy workforce is strongly aligned with business success. A healthy workforce can increase productivity, reduce absenteeism, generate higher retention and better overall engagement.
Download our webinar "Strategies to Promote Employee Health and Wellbeing" and discover insights that can be used by employers of all sizes to begin to increase health and safety of employees while reducing cost. You will find tips to implement right away and insights to share with senior leadership.
Uncovering Best Practices from Corporate Integrity AgreementsMD Ranger, Inc.
A CIA is a tool used by the OIG to address violations at healthcare organizations through policies and procedures designed to enforce compliance with regulations. A CIA is usually coupled with a civil settlement between the provider and the government to avoid exclusion from federal health programs.
In this presentation, we will discuss how to use recent CIAs to derive best practices that can benefit your organization.
We will cover:
-Common guidelines found in multiple CIAs
-Best practices from CIAs for specific types of healthcare entities
-Easy ways to improve your physician contracting compliance
-And more!
In a country of more than 313 million people, the pressures placed on the health care system in the United States are both enormous and complex, as Americans expect a fundamental right to first rate health care without much regard for its cost.
However, the Federal and California governments are mindful of this expense and
take pride in their important role in regulating health care on the West Coast. This is a guide for responding to these investigations.
Chapter 3Risk Management in EmploymentEmployment Re.docxketurahhazelhurst
Chapter 3:
Risk Management in Employment
Employment Relationship carries Risk
• Risk to an organization is not limited to
provider-patient relationships
• As in any business, the healthcare organization
has responsibilities to its employees. Many of
which, if not properly implemented/enforced,
can lead to negative and litigious results
Employment-at-Will
• An employer may dismiss an employee
hired for an indefinite period of time for
any reason or no reason at all without
incurring liability to the employee
• Caveat: cannot discharge for an unlawful
reason, such as racial discrimination
Implicit Employment Contracts
• Though most states follow the employment-at-
will doctrine, many organizations may
unknowingly negate their ability to apply this
principle through
– Employer policies (i.e. progressive disciplinary policy)
– Oral assurances (i.e. looks like you have a bright
future ahead of you here)
– Industry customs (i.e. after so many years in one
position, employees are promoted to the next level)
– Employer conduct (i.e. allowing some employees
more chances to correct errors than others)
Burden of Proof
• In civil litigation of discrimination, the burden of
proof is usually on the plaintiff -they must show:
• Membership in a protected group
• Satisfactory job performance or appropriate
qualifications for the job being sought
• Receipt of discipline, termination or rejection
despite having the qualifications
• Employees of another protected class were
disciplined less severely or the employer continued
to accept application of people who were no better
qualified
Sexual Harassment
• Unwelcome sexual advances, request for
sexual favors or other verbal or physical
conduct of a sexual nature when it is one of
the following:
• is a condition of employment
• is the basis of employment decisions
• interferes with work performance
• creates a hostile work environment
Minimizing Risk of Sexual Harassment
• Organization must exercise reasonable care to
prevent and correct any sexually harassing
behavior
– Written policies/procedures
– Documented staff training on policies/procedures
– Consistently adhere to and enforce policies
– Immediately investigate allegations of sexual
harassment
Responsibility of the Employee
• Employee must report occurrences of sexual
harassment to employer
– Employer must be given the opportunity to investigate
and take corrective action
• Though it is important that an employer investigate
all reports of sexual harassment, proactively
addressing situations or behavior that may be
perceived as sexual harassment is imperative.
– If management is aware of a potential situation and does
nothing, the risk of litigation and penalty is increased
People with HIV or AIDS
are protected by the ADA
Persons with HIV disease, both
symptomatic and asymptomatic, have
physical impairments that substantially
limit one or more major li ...
2. Purpose of P&S Corporate Compliance
To have an effective compliance and ethics program:
• To exercise due diligence to prevent and detect wrong-doing
• Promote an organizational culture that encourages ethical
conduct and a commitment to compliance with the law.
• Raise awareness
• Positive impact to corporate reputation/culture
• Provide a “safe” mechanism(s) for reporting and seeking help
3. Objectives of P&S Corporate Compliance
To meet the objectives of the 7 elements of a corporate
compliance program as out line by the (FSG) Federal
Sentencing Guidelines:
• Review Written Policies & Procedures
• Select Compliance Officer & Committee
• Training & Education
• Effective Lines of Communication
• Discipline & Background Checks
• Auditing and Monitoring
• Responding & Corrective Action
4. Written Policies & Procedures
• Develop and implement policies, procedures, and
practices designed to ensure compliance with state &
federal regulations and programs.
• P & S adheres to the requirements set forth in policy &
Code of Conduct by federal and state regulations
(e.g., licensure, Medicare/Medicaid requirements, HIPAA/HITECH requirements, etc.).
5. P & S Code of Conduct:
• Deter, Detect, Correct & Prevent Misconduct
• 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
6. P & S Code of Conduct:
• The Code of Conduct provide standards by which all members of
the organization will conduct themselves.
• Individuals conduct must be in a manner that protects and promotes
organizational-wide integrity and enhances P & S Surgical Hospitals’
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.
• Staff members must certify annually that they have received,
read, understand, and agree to abide by Code of Conduct.
7. Compliance Officer & Committee
• Continue to design, implement, oversee, and monitor the compliance
program
• Report on a regular basis to the CEO, compliance committee, and when
necessary to the governing body.
• Develop, coordinate, and participate in a multifaceted educational &
training program.
• Ensure that independent contractors and agents are aware of the
organization’s compliance program requirements.
• Assist with internal compliance review and monitoring activities.
8. Training & Education
• Communication process to report any compliance issues or concerns
• New Hire Initial 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.
9. Effective Lines of Communication
Reporting Compliance Issues or Concerns:
1. Your manager
2. Executive Team Member
3. Director of Human Resource
Chenire Craig- 998-7307
4. Compliance Officer
Compliance “Anonymous” Hotline - 1-866-570-2523
10. Effective Lines of Communication
• Dirk Rhodes, Corporate Compliance Dept.
• 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 place.
11. Discipline / Background Checks
• All employees undergo a background check/ drug screening upon
initial hiring.
• A monthly SanctionCheck is preformed on all employees, medical
staff, and vendors to show that P&S is compliant with federal &
state regulations and 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 chain in the event of misconduct.
12. Auditing & Monitoring
• Unethical or inappropriate care • MCR inpatient one day
of patients stays
• Lack of correct and sufficient • Conflict on Interest
documentation in admitting / /Inappropriate vendor
discharging patients relationships
• Medical Necessity • Inappropriate access
and/or release of (PHI)
• Billing for services or supplies
that were not provided • Bribes or kickbacks
• Altering claims for higher • Business Associate
payment Agreements (BAA)
• 2 Annual (External) • Physician Ownership
Billing/Coding Audits Disclosure
13. Responding & Corrective Action
• The Compliance Department reviews all allegations in a serious matter and take 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 place.
• 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.
• 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!!
14. 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 taken against those who commit
misconduct
• Prohibits asking for or receiving anything of value to induce or
reward referrals of Federal health care program business
15. 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 (>$10.00 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
16. Case Study
(Example)
I am a nursing assistant on one of the patient care floors. Recently,
while cleaning a bathroom, a housekeeper, Sam, was stuck by a
needle that had been mislaid in the bathroom. Sam was concerned
about whether the patient was HIV positive, so he called his friend,
Rose, a technician in the lab, and asked her to check and see whether
there had been an HIV test performed on the patient whose
bathroom he has been cleaning. Rose did check and told him that a
recent HIV test was negative.
17. Q&A
1. What's wrong with this picture?
Patient Confidentiality
Infection Control
2. Which Facility policies does this relate to?
Guidelines for the Prevention of Transmission of Blood-borne Pathogens in the Workplace
Employee Incident/Accident
Code of Conduct
3. What are some choices for how you can handle this?
Wash the site
Report to a nurse supervisor about the needle stick
Fill out an occurrence report to the nurse supervisor/infection control officer
See the infection control officer for testing and further instuctions
4. Who can help if you are unsure about what to do?
Infection Control Officer
Director of Nursing/Supervisor
Executive Team Member
Compliance Officer/Hotline
Human Resources
18. 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!!