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Compliance Officers. Jane Dutton Morris, MHACompliance Specialist, Sierra Pacific Network (707) 562-8377 Jane.Dutton2@.va.gov Yvonne Brooks, CCP Compliance Officer VA San Francisco Medical Center(415) 221-4810 Ext. 4398Yvonne.Brooks@med.va.govCaroline Chaderjian, MHACompliance Officer
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1. VHA and VISN 21 Compliance & Business Integrity (CBI) Program Mandatory Training for Contractors
Prepared: March 2007 VHA and VISN 21 Compliance & Business Integrity (CBI) ProgramMandatory Training for ContractorsPrepared Jan. 2006VHA and VISN 21 Compliance & Business Integrity (CBI) Program
2. Compliance Officers Jane Dutton Morris, MHA
Compliance Specialist, Sierra Pacific Network
(707) 562-8377
Jane.Dutton2@.va.gov
Yvonne Brooks, CCP
Compliance Officer
VA San Francisco Medical Center
(415) 221-4810 Ext. 4398
Yvonne.Brooks@med.va.gov
Caroline Chaderjian, MHA
Compliance Officer
VA Palo Alto Health Care System
(650) 493-5000 Ext. 63315
Caroline.Chaderjian@va.gov
Patty Almond, RHIT, CPC
Compliance Officer
VA Central California Health Care System
(559) 225-6100 Ext. 5581
Patricia.Almond@va.gov
Compliance Officers:Jane Dutton MorrisYvonne BrooksCaroline ChaderjianPatty AlmondCompliance Officers:
3. Compliance Officers- continued
Patricia Moran, RHIT CPC
Compliance Officer
VA Northern California Health Care System
(707)437-1905
Patricia.Moran@va.gov
Peggy Ashcraft
Compliance Officer
VA Sierra Nevada Health Care System
(775)328-1212
MargaretPeggy.Ashcraft@med.va.gov
Craig Oswald, MHA
VA Pacific Islands Health Care System
(808)433-0103
Craig Oswald@med.va.gov
4. VHA Definition of Compliance Compliance is an oversight process which requires employees and contractors to conduct administrative and clinical duties in an honest, ethical and professional manner.
Behavior that is not consistent with ethical business practices places Veterans Health Administration (VHA) facilities at risk for penalties, negative publicity and loss of public trust.
5. VHA’s Compliance Program Currently the VHA’s Compliance & Business
Integrity program focuses on the
REVENUE CYCLE to include the following
business operations:
1) Patient registration & intake
2) Medical documentation
3) Coding for medical procedures & visits
4) Billing for services provided
5) Collections from insurance companies
6. Purpose of VHA Compliance Program
Ensure business operations comply with relevant laws, rules and regulations;
Promote ethical practices and standards of excellence in patient care;
Help VHA maintain the public’s trust.
7. Effective Compliance Program An Effective Compliance Program Has 7 Elements:
1. Designating Compliance Officer & Committee
2. Written Policies and Procedures
3. Education and Training
4. Auditing and Monitoring
5. Reporting Mechanisms
6. Investigation and Remediation
7. Disciplinary Action
8. Medical Documentation, Coding & Billing by Contractors Physicians or healthcare providers are responsible for completely and accurately documenting patient care services.
Coders are responsible for assigning and validating procedural & diagnostic codes based on provider documentation.
Billers are responsible for generating timely, accurate and appropriate bills based on veterans’ eligibility and the service provided.
Accurate and complete services reduce the negative
consequences associated with fraud and maximize
reimbursement from insurance companies
which, in turn, allows
VHA to provide more services to our patients.
9. Open Lines of Communication
10. CBI Helpline- continued
The CBI Helpline is available Monday through Friday from 8:00 to 4:300, EST. Anyone “internal” or “external” to the VA (this includes employees, patients or contractors) may call the CBI Helpline number to report potential compliance failures.
The caller may remain anonymous.
11. HIGH RISK AREA
A high risk area is a clinical or business activity that may be
unethical, illegal, a conflict of interest or in violation of national and
local policies & procedures.
Employees and contractors should:
Be aware of high risk areas concerning VHA
Not engage in fraud or abuse against VHA
Take appropriate actions- report all potential
compliance failures to the VHA facility Compliance
Officer and/or the CBI Helpline.
12. EXAMPLES of High Risks
Fraudulent Coding : Up-coding (using higher codes) to get higher
reimbursement from 3rd party insurance companies.
Erroneous Billing: Billing for services not provided to the patient;
Billing for Services Provided by Residents (physicians in training) without
adequate supervision by a credentialed physician.
Providing Medically Unnecessary Services: Providing services that the
patient does not need or may cause the harm to the patient.
Failure to Report a Suspected Compliance Violation: knowing about a
potential compliance failure and not reporting it.
13. EXAMPLES of High Risks (continued)
Failure to Exert Due Diligence: Contracting with individuals or
companies that have a propensity to engage in illegal activities.
Kickback: Soliciting or receiving payment / gifts in return for referring a
patient to another healthcare provider or for conducting business with a
certain entity.
Appearing on the OIG Sanction List: Sanctioned individuals, entities,
contractors listed on the Office of inspector General’s (OIG) Exclusionary
List Database cannot receive payments from any federal healthcare
programs for services furnished.
14. Identifying & Reporting High Risk Areas STEP 1: Ask yourself some key questions
Does the action fit with the organization’s values?
Would you feel good about yourself if you did it?
Would you be comfortable discussing this with your family and friends?
If you answer “no” to any of these questions, you should go to the next step.
STEP 2: Discuss your concern with the facility Compliance Officer and/or call the CBI Help-Line at 1-866-842-4357
15. Federal Employee and Contractor Responsibilities
1. Contractors should not offer gifts to federal employees and federal employees should not accept gifts from entities that do business or are attempting to do business with the organization
2. Federal employees should excuse themselves from activities in which they might have a financial interest
3. Federal employees must remain impartial in conducting official duties.
16. SUMMARY Compliance is Everybody’s Responsibility;
Know who the Compliance Officers are
and how to contact them;
Follow your own best instincts;
Do your job ethically & legally;
Be honest in all business transactions/ and contracts / awards.