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HEALTHCARE TRUSTEES OF NEW YORK STATE

HEALTHCARE TRUSTEES OF NEW YORK STATE. Compliance and Governance Update August 8, 2012. Realities. Renewed Federal Interest in Governance Health Reform Brings Governance Challenges State Government’s Reach May Exceed Its Grasp Board Oversight of Issues is Expanding. A Few of the Issues.

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HEALTHCARE TRUSTEES OF NEW YORK STATE

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  1. HEALTHCARE TRUSTEES OF NEW YORK STATE Compliance and Governance Update August 8, 2012

  2. Realities • Renewed Federal Interest in Governance • Health Reform Brings Governance Challenges • State Government’s Reach May Exceed Its Grasp • Board Oversight of Issues is Expanding

  3. A Few of the Issues • Executive Compensation • OMIG Compliance Guidance • Recovery Audit Contractor (RAC) and Other Audits • Expanded Surveillance Focus – Quality • Conflicts of Interest • Increased IRS Scrutiny

  4. Executive Compensation • Executive Branch Process • Limits on Reimbursement, Compensation and Use of State Revenue • Very Expansive Reach • “Covered Executive” Definition • “Related Entity” Definition • Hospitals are Not Focus But are Covered

  5. Aggressive Government Audits • Carried Out by Contractors • Often Paid on Contingency Basis • RACs, MACs, ZPICs, CERTs, Comprehensive Medicare Compliance – To Name a Few • Very Burdensome Document Demands • Clinical Judgment Calls

  6. Government Audits (cont) • All-or-Nothing Recoveries • Hundreds of Millions of $$ At Issue • Post-Payment Reviews • Pre-Payment Reviews • Lengthy Appeals Process • Comprehensive Medicare Audits – OIG • Internal Controls • Process from Patient to Claim Submission

  7. Office of Medicaid Inspector General (OMIG) Compliance • OMIG Now Organized by Teams • Hospital Compliance Guidance - May ’12 • Compliance Audits Will Increase as “Gotcha” Decreases • Document Request Includes Board Minutes • Expectation of Broad Board Oversight • Directors Interviewed During Audit

  8. Governance and Quality • Increased Regulatory Focus on Quality Oversight • Prompted by Feds; Implemented by State • Focus on Full Board Awareness • Reports to Board Committee May Be Inadequate • Dovetails with OMIG Compliance Program Expectations

  9. Conflicts of Interest • Doing Business with Hospital • Trustee Joint Venturing • State – Attorney General, Governor • Federal – IRS, Fraud Agencies • Board Minutes Should Reflect Transparency

  10. Internal Revenue Service • Proposed Rules – Community Benefit Reports • Providing Charity Care Not Enough • Mandatory Reporting of Financial Arrangements – Directors • With Each Other & With the Facility

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