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PRESENTATION OUTLINE

CORPORATE COMPLIANCE Tim Timmons Vice President Compliance and Regulatory Services Health 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.

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PRESENTATION OUTLINE

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  1. CORPORATE COMPLIANCETim TimmonsVice President Compliance and Regulatory ServicesHealth Future, LLC

  2. 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

  3. WHAT IS A CORPORATE COMPLIANCE PROGRAM

  4. 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.

  5. WHY DO WE NEED ONE?

  6. 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

  7. 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

  8. RECOMMENDED PROGRAM ELEMENTS

  9. 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

  10. OIG PROGRAM GUIDANCE • The compliance program shouldincludeall 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

  11. WRITTEN POLICIES ANDPROCEDURES • 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

  12. 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

  13. 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

  14. 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

  15. 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

  16. 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

  17. AUDITING/MONITORING – OIG PROGRAM GUIDANCE Hospitals Laboratories Home Health Hospice Long Term Care DME Physician Offices Third Party Billing Medicare + Choice Rx Manufacturers

  18. 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

  19. WHAT MAKES A PROGRAM EFFECTIVE?

  20. 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

  21. PLAN FOR ASSISTING AWPHD HOSPITALS

  22. 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

  23. QUESTIONS?

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