PRESENTATION OUTLINE
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Transcript of PRESENTATION OUTLINE
CORPORATE COMPLIANCE
Tim TimmonsVice President
Compliance and Regulatory ServicesHealth Future, LLC
CORPORATE COMPLIANCE
Tim TimmonsVice President
Compliance and Regulatory ServicesHealth Future, LLC
PRESENTATION OUTLINE
WHAT IS A CORPORATE COMPLIANCE PROGRAM
WHY DO WE NEED ONE RECOMMENDED PROGRAM ELEMENTS WHAT MAKES A PROGRAM EFFECTIVE PLAN FOR ASSISTING AWPHD HOSPITALS
WHAT IS A CORPORATE COMPLIANCE PROGRAM
WHAT IS A CORPORATE COMPLIANCE PROGRAM
A program that articulates the hospitals’ commitment to the provision of health care services in full compliance with all federal, state and local laws and regulations, and that sets forth a plan for proactively preventing, detecting, and reporting violations of the laws and regulations which govern the services that they provide.
WHY DO WE NEED ONE?
REASONS TO DEVELOP A CORPORATE COMPLIANCE
PROGRAM
Operationalizes the commitment to ethical and lawful behavior
Reduces the liklihood of violations and employee whistleblowing
Reduces exposure to civil and criminal liability Enhances public credibility
REASONS TO DEVELOP A CORPORATE COMPLIANCE
PROGRAM Provides assurance of lawful behavior to Board
and senior management Provides for mitigation of sentences if
convicted of criminal fraud Protects Board members and officers -
Caremark decision Improves the speed and quality of responses to
lawsuits or investigations
RECOMMENDED PROGRAM ELEMENTS
OIG PROGRAM GUIDANCE Compliance policies and procedures Oversight by high-level personnel Discretionary authority vested in reliable
individuals Effective training and education Auditing and monitoring Consistent disciplinary mechanisms Appropriate responses to detected violations
OIG PROGRAM GUIDANCE
The compliance program should include all seven of the elements required by the U.S. Sentencing Commission and OIG Guidelines
The recommendations of the OIG’s Compliance Program Guidance for Hospitals must be considered, depending upon their applicability to each particular hospital. The hospital should be prepared to justify non-compliance with any recommendations
WRITTEN POLICIES AND PROCEDURES
The Hospital Code of Ethics is the foundation of the compliance program
Each employee should sign an attestation that he/she will abide by the Code and the compliance program
Policies and procedures should be developed for the hospital as a whole, and for the high risk areas
OVERSIGHT BY HIGH-LEVEL PERSONNEL
Designation of a corporate compliance officer May be a part-time responsibility Responsible for coordinating the planning,
implementation and monitoring of the program Direct access to the CEO and the Board, regardless of
his/her direct reporting relationship Establishment of a compliance committee
EFFECTIVE EDUCATION AND TRAINING
Required of all hospital staff, employees, physicians, independent contractors and other significant agents
New employees must be educated early Training in other languages for culturally diverse
staff should be used Number of hours of training should be specified
• High-risk areas should receive more training• Training must be documented
EFFECTIVE LINES OF COMMUNICATION
Access to the compliance officer necessary Develop non-retaliation and confidentiality policies Advise employees that anonymity can’t be
guaranteed Employees should report all suspected misconduct Document employee questions and answers,
investigations and results Use of hotlines is encouraged if needed
DISCIPLINARY ENFORCEMENT
Discipline should be consistently enforced Background investigations should be
conducted for new employees who have discretionary authority to make decisions that may involve compliance or who have compliance oversight
AUDITING/MONITORING
All OIG Work Plan risk areas should be reviewed over the course of the year
Additional high-risk areas should be reviewed based on priority
The effectiveness of the compliance program should be formally evaluated annually
AUDITING/MONITORING – OIG PROGRAM GUIDANCE
Hospitals Laboratories
Home Health Hospice
Long Term Care DME
Physician Offices Third Party Billing
Medicare + Choice Rx Manufacturers
RESPONSES TO DETECTED VIOLATIONS
Steps should be taken to immediately correct problems detected
Report misconduct to the appropriate governmental agency not more than 60 days after discovering credible evidence of a violation
Investigate suspected violations ASAP Overpayments should be promptly refunded
WHAT MAKES A PROGRAM EFFECTIVE?
WHAT MAKES A PROGRAM EFFECTIVE?
Support of board and executive staff Ongoing education of staff, particularly in the high-
risk areas Monitoring and auditing (reviewing) high-risk areas Consistency in enforcement HCCA publishing effectiveness criteria
PLAN FOR ASSISTING AWPHD HOSPITALS
PLAN FOR ASSISTING MEMBER HOSPITALS
Provide a model comprehensive compliance program, addressing all high-risk areas
Provide compliance education to key hospital personnel
Update AWPHD hospitals on significant new compliance developments
Provide compliance tools for effective program implementation
Provide compliance consultation
QUESTIONS?